In June 2007 the European Council of Agricultural Ministers agreed to a new Council Regulation on organic production and labelling of organic products. This new Council Regulation contains clearly defined goals, principles and general rules for organic production.
This, together with regulation (EC) 1235/2008, which recognized Australia as a third country from which imported products can be sold into Europe as organic, marks a significant landmark in the exporting of products certified by ACO into Europe.
Although the placement of the EU logo is voluntary for imported products, use of the euro-leaf logo will contribute to the recognition of your product’s organic status when exported to Europe.
For ACO certified operators based in Australia there are two ways to export to Europe as organic.
1. National Standard for Organic and Biodynamic Produce (Australian Government equivalency). (Australia Only)
Plant and Plant Products exported as food (excluding wine and yeast). All ingredients used in these products must be Australian Grown and may not contain imported organic ingredients.
Products exported under the National Standard government equivalency complete Export Certificate EX1399 and comply with Council Regulation (EC) No 834/2007, Article 33(2).
2. Australian Certified Organic Standard (EU recognition)
Australian Certified Organic have a direct EU recognition of the Australian Certified Organic Standard, for scopes and countries not covered under government equivalencies. The full list can be found in regulation Annex IV of EC 1235/2008.
For operators based in Australia scopes covered under EU recognition are as follows wine, livestock products e.g. Honey, processing operations using imported EU certified ingredients.
Products exported out of Australia which fall under ACO direct EU recognition need to complete Export Certificate 1399 and comply with Council Regulation (EC) No 834/2007, Article 33(3).
ACO operates extensively throughout the Asia pacific region and have EU recognition for over 20 countries. Please refer to regulation Annex IV of EC 1235/2008 for the full list of countries. Products exported to Europe by ACO clients operating in countries listed in regulation Annex IV of EC 1235/2008 need to complete the ACO EU transaction certificate template and comply with Council Regulation (EC) No 834/2007, Article 33(3).
EU certified operations may use the EU leaf logo. The logo and labelling guidelines can be downloaded from the EU website http://ec.europa.eu/agriculture/organic/downloads/logo/index_en.htm
Products carrying the EU logo or being exported to Europe must ensure:
– At least 95%of the products ingredients are of agricultural origin and have been organically produced to a standard recognised by the EU.
– All products comply with ACO inspection and control measures
– All products must bear either the name of the producer/preparer or vendor.
– The correct EU code of the inspection body
– Conversion labelling in not permitted
Product exported to Europe requires the mandatory EU code to be on the label. ACO has two EU codes as detailed below:
Product which is certified to the National Standard and meets the requirements of Department of Agriculture.
Product produced in Australia – which includes wine, livestock/or livestock by-products, plant processed product which contains imported EU certified ingredients. Product produced internationally in a country where ACO has EU recognition e.g. Fiji, China, Vanuatu (as per EU regulation 1235/2008)
Australian Certified Organic EU Control Measures (ACO/EU Recognition)
Operators interested in exporting to the EU which fall under ACO’s direct recognition with the EU must go through the following process in order to gain EU certification:
1. Complete the ACO application form requesting EU certification
2. Read and understand the requirements set out in the Australian Certified Organic Standard
3. Complete the Organic Management Plan and Statutory Declaration and submit to the ACO office. Adequate relevant supporting documentation must also be submitted.
4. Following the receipt of the documents listed above the application will be allocated to certification. Certification will review the application for compliance. Where non-compliances are raised, or insufficient information in supplied, it is the responsibility of the applicant to ensure that such issues are addressed within a defined timeframe set the by certification.
5. Following approval of the application an onsite inspection will be allocated. Inspections are subcontracted to professional organic inspectors conversant with the requirements of the Australian Certified Organic Standard and additional EU requirements. In addition to scheduled inspections, unannounced and additional inspections may be carried out at ACO’s discretion.
6. The inspector will complete the onsite inspection at a time and date which is convenient for both parties.
7. The inspector will submit the complete inspection report to the ACO office along with any additional documents. The inspection will then be reviewed by the Certification Review Committee. A decision will be made to either grant certification or if additional information/Corrective Actions are required.
8. Once all requests are satisfactory closed ACO will issue a organic certificate of compliance for the relevant program/service.
An inspection will be carried out at a minimum once every 12 months. You may also receive an unannounced inspection throughout the year as ACO conducts minimum 10% unannounced inspection on all EU operations.
If an operation is deemed high risk then may receive an additional inspection, separate from your annual inspection. ACO has developed a set of risk criteria as below which is used to identify high risk operations:
- Has there been any 30 Day Corrective Actions related to organic integrity of the product raised during the audit or in the last 12 months?
- Have there been any recurrent 30 Day or Next Audit Condition Corrective Actions?
- Has the client received an Intent to Suspend for certification compliance issues in the last 12 months (non-accounts related)?
- If the operation has parallel production has there been any compliance issues raised in the last 12 months related to product integrity?
- Have any complaints which have lead to an investigation resulted in Major Corrective Actions in the last 12 months?
- Have any soil/tissue/product test conducted in the last 12 months showed non acceptable levels of contaminants?
- Have the client organized a certified organic product recall in the last 12 months?
ACO clients’ products or produce shall be tested on an annual basis based upon risk assessment and shall at a minimum constitute 5% of all certified organic operations. Sample testing may include but is not limited to standard Organochlorines and Organophosphate screens, heavy metal tests, other modern agrichemicals including herbicides, GMO presence, SO2 in non allowed products, etc.
For further information about exporting the Europe or gaining EU certification please contact the ACO Client Support Office.