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Hundreds of smallholder groups, thousands of farmers
There are currently about 350 different grower groups existing in Less
Developed Countries, comprising close to 150,000 smallholders, whose
organic products are exported to markets in the North. It is estimated
that smallholders produce up to 70% of organic products imported into
Europe. (2nd International workshop on smallholder certification, Feb. 2002)
Restrictive norm and regulation
Organic certification norm and regulations, e.g. the European
regulation, requires an annual inspection visit of every producer.
Local third party organic certification bodies are often not available
in most developing countries today. For most smallholders in developing
countries, it is impossible to pay for annual inspection visits by a
foreign third party certification body.
Quality assurance systems for groups
Long before government regulations, since 15 years ago, smallholders in
developing countries in co-operation with certification bodies have
been developing systems to assure compliance to organic standards for
producers as a group. Different forms of quality assurance systems of
smallholder groups have developed over time with respect to the nature
of the operation and size, ranging from tens to thousands of individual
producers. The systems have in common the following aspects:
A central body responsible for marketing and the group's compliance to
applicable standards. (buyer, processor, or self organized
cooperative/association)
One single certification for all individual production as well as
processing and handling activities registered within the group.
Individual operators within the group may not use the certification
independently.
Group members operate under contractual or binding membership
requirements specifying the commitment to comply with applicable
organic standards and permit inspection, etc.
Presence of an internal control system (ICS), operated by the
responsible central body or an external body contracted by the central
body. The ICS normally maintains files on all members of the group and
inspect each member's operation at least once a year. A list of all
individual member producers is available.
The Group through the ICS mechanism decides on members' compliance to
applicable standards. Non-compliances are dealt with according to set
procedures and sanctions.
Measures to handle appeals and complaints are also in place for some groups.
Two tier guarantee
Organized groups benefit individual producers as well as enhance
quality assurance. They offer more resources and higher capacity for
compliance and maintenance of organic integrity. Internal control
systems (ICS) are effective quality assurance tools, particularly in
developing countries.
Situated in the locality, ICSs can manage a higher and better
surveillance regime than external annual visits. Internal control
visits are often performed more than once a year, in many cases up to
three times. The local organization knows the agricultural conditions
and local culture better than external inspectors and certification
officer/committees based outside the country. ICSs also serve as
effective extension support for smallholders, in areas where none is
available, to convert and improve organic practices.
Coupled with an annual inspection of the operation cum evaluation of
the ICS, Group certification offers two tiers of control as opposed to
just an external annual inspection visit. Furthermore, the flow of
produce from individual producers is under greater control with
centralized marketing as a group. The maze of transactions between
different separate actors is a major cause of fraud in organic,
especially when they are certified by different certification bodies.
There is no effective mechanism in place for serious crosschecking of
transactions today. With group certification, at least one level of
buyer is integrated as part of the group. This integration reduces the
number of separate actors and certifiers in a specific supply chain.
Effective quality assurance tool for different situations
It is clear that the current one farm, one annual inspection model
cannot address all the different socio-economic-cultural conditions
that agriculture takes place in. Group Certification, incorporating
internal quality assurance systems, can address situations that the
current model cannot. Smallholder group certification is one such
situation.
International criteria for smallholder group certification are elaborated in the IFOAM norms.
There is also support for such certification in ISO guide 53. Never the
less, Group certification, is treated as an exception by regulators. It
remains a gray area and is handled in a haphazard manner by both
regulators and private certifiers.
Growing acceptance but differing requirements
The NOSB Accreditation Committee issued a draft recommendation (April
17, 2002), on Criteria for certification of Grower Groups. They also
conclude that as "cooperative" and "association" are included in the
definition of "person" (section 205.2, of the Final Rule), grower
groups, organized as cooperatives or associations, can seek
certification as one operation under the NOP without a change to the
Final Rule. The requirements for Production Process Manager (PPM), a
category for JAS organic certification under the Japanese organic
regulation is reportedly set with a group organization in mind. (The
Organic Standard, May 2002). The EU Commission is currently preparing
guidance for smallholder group certification.
Whilst the growing recognition of Group certification is encouraging,
differences between regulations and approaches can still pose
devastating burdens on under resourced small operators and defeat the
purpose. In the European Union, member states decide on import
authorizations and may set their own requirements. Different competent
authorities have set different requirements for group certification.
Differing requirements between EU member states, as well as differences
between major importing markets, e.g. EU, US and Japan, will only serve
to further complicate an already complicated situation, especially for
groups who export to several different countries.
Certification bodies also have different approaches to group
certification, e.g. what an internal control system (ICS) should
include as well as inspection protocols for such situations. These
varying approaches often make it difficult for one certifier to accept
another certifier's certification, leading to double and sometimes
triple inspections and certifications.
Need for a common approach
The need for a common international approach is essential. With more
than 50 countries, who have either set or are in the process of setting
organic regulations, the need for international harmonization between
regulations as well as private sector standards was unanimously held as
top priority at the International Harmonization conference co-hosted by
the FAO and IFOAM, in Germany, Feb. 2002.
IFOAM'S POSITION
Principles
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IFOAM is firmly committed to high quality inspection and certification
requirements for organic products traded in the open market place.
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IFOAM supports that standards, inspection and certification
requirements shall be well adapted to the local situation, requiring
different measures depending on the risk of fraud, the actual
production situation, etc.
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IFOAM believes that the scale of production and value of marketable
crops are relevant considerations. Inspection and certification costs
shall not discriminate against or force small operators, who follow
organic standards, out of the market.
On Small Holder Group Certification
Certification should be an enabling mechanism rather than a technical
barrier to market access and trade. IFOAM is convinced that the system
of having a functional ICS together with an annual
inspection/evaluation* by a third party certification body offers a
sound if not better organic guarantee system. The system offers two
levels of control as opposed to one. It encourages group organization,
which enhances the overall capacity of individual members within the
group to institute and further develop Good Management Practices.
IFOAM urge national authorities and organic certification programs to:
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recognize the effectiveness and relevance of group certification for small holders in developing countries.
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support the development of self-administered quality assurance systems with external evaluation based on agreed set criteria
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develop mutual recognition of certification based on
inspection/evaluation according to international set norms and
oversight by an international accreditation system.
On a common approach (international criteria and oversight)
IFOAM has been developing criteria for grower group certification since
1994. The current criteria include requirements for a viable internal
control system that assures compliance of individual operators in an
objective manner. They adopt the approach of utilizing a supplier's
quality system for third party certification, in line with ISO guide 53.
Over 25 certification bodies are currently working with smallholder
group certification. About 10 of them are IFOAM accredited and comply
with the IFOAM criteria for smallholder group certification. Their
implementation of smallholder group certification is monitored by the
International Organic Accreditation Services (IOAS), the US registered
not for profit international organic accreditation body that operates
the IFOAM Accreditation program. Certification by an IFOAM Accredited
certification body (ACB) is normally accepted by another ACB, in line
with the terms of the multilateral agreement between ACBs.
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IFOAM urges governments not to design prescriptive regulations for group certification.
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We urge national authorities and private organic certification bodies
to work on a common approach, encompassing international criteria and
oversight.
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IFOAM offers to facilitate in partnership with other interested bodies,
the setting of international criteria based on a consensus between all
major stakeholders, e.g. government authorities, certification bodies
and producer groups.
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IFOAM also offers the IFOAM Accreditation program as a mechanism to monitor compliance to set criteria.
Consensus development on internal quality assurance systems and Group Certification for organic production and processing.
An initiative to develop consensus on smallholder group certification has been sponsored by
IFOAM. The process is organized by a consortium of organizations and
open to all major stakeholders, e.g. producer groups, certification
bodies and competent authorities worldwide. The process is now in its
third year.
The first international workshop was held in Germany, February 2001,
and dealt especially with the requirements for producer groups to be
eligible for smallholder group certification. The second international
workshop also held in Germany, February 2002, was organized especially
for certification bodies and concentrated on the evaluation protocol,
the elements that need to be evaluated, the appropriate re-inspection
rate, risk-assessment tools and content of the recommendation for
certification. A workshop held in conjunction with the IFOAM Organic
World Congress, in Victoria, Canada, August 21, 2002, followed up
discussion on inspection rate, non-conformities and sanctions as well
as a definition for smallholders. A concluding international workshop
is scheduled for Feb 2003, in Germany. Reports and workshop documents
are available from IFOAM.
Consensus on a number of aspects have been reached, namely
Definition of Internal Control Systems and the basic elements of an ICS (1st workshop).
The evaluation protocol, elements that need to be evaluated and content of recommendation for certification (2nd workshop).
Consensus on inspection rate(s), non-conformities and sanctions as well
as a definition for smallholders is expected in the concluding workshop.
- IFOAM urges national authorities and private organic
certification
bodies to participate fully in the consensus building initiative. The
WTO TBT agreement and ISO recognize that third party certification
systems should to the extent possible be based on internationally
agreed standards and procedures. They encourage national systems to
seek equivalence with one another so as to facilitate bilateral and
multilateral agreements. ISO also recognizes the major role of
manufacturers' declarations of conformity in normal
manufacturer/customer relationship.
Submission to the European Union and member states
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