to poor environmental conditions and a lack of respect for the environment. A few mention that they have “personally” seen farmers
spray an organic field, but didn’t identify the farm, or the date when it
happened or what was sprayed. In fact, as we have seen, there are relatively few instances where organic ingredients from China (or other
countries, for that matter) have been found to be contaminated.
delivered in cargo boxes, which are
often not packaged and labeled, have
the highest risk of fraud. Figure 1
shows several combinations of transactions and the related risk.
“T“There is nothing better to secure the organic
integrity of a product than a long-standing,
trusted relationship.”
It should be noted that China is not the only country that falls into
this category, although there are no others on China’s scale with more
than 10 million acres of certified organic land. Some producers out of
India, the Philippines and Peru may also require extra quality control
measures.
Product-related Risks. These are intrinsic to certain products such
as grapes, strawberries, cotton and hops, which are conventionally
grown with heavy pesticide input, oftentimes requiring more than 10
spraying runs per growing season. Since it requires specific skills to
grow these products organically, the risk of prohibited pesticide application is higher than for items such as potatoes.
Complexity of Transaction Risks. This occurs when a transaction
has multiple partners. The more traders involved, the less transparent
the transaction. An example of this scenario would be a product
grown by an African farmer for an Indian company sold to a U.S.
trader and from there to a U.S. manufacturer, which is a scenario that,
while not commonplace, has become reality in recent years.
Spot-buying Risks. Having to buy ingredients on short notice brings
its own set of risks due to little time and limited opportunity to check
the organic integrity of the products bought. Having scheduled pro-
Low Risk Medium Risk High Risk
Direct purchase Packaged goods, High-risk origin (imported)
Long-term relationship Medium-risk origin (imported) Bulk
Packaged goods One trader Short notice
Short track record Several traders
No track record
Figure 1
duction runs for complex products and realizing that one ingredient
is missing creates pressure, where the goal of getting the ingredient
often overrules the necessary due diligence.
Lack of Creditable Track Record Risks. Some traders and producers have no track record at all, or one that is questionable. While one
case of inappropriate attention to organic integrity cannot necessarily
be held against that producer or trader forever, an impeccable track
record is an important asset and certainly means lower risk.
Non-labeled Bulk-product Risks. Bulk products such as feed grain
A Reasonable Risk Assessment
Approach
It has become clear by now that
regular quality control systems such as
a HACCP (Hazard Analysis and Critical Control Points) system, while only
mandatory for juice, seafood, meat
and poultry, are even more important
for organic manufacturers than for
their conventional counterparts. The
steps outlined below should be integrated into the HACCP or similar
control system employed by the manufacturer or packer.
First of all, there is nothing better
to secure the organic integrity of a
product than a long-standing, trusted
relationship between a supplier or
trader and a manufacturer in concert
with the properly documented organic certification for all products
and the respective quality control
system.
If that’s not the case, a risk assessment should be conducted, taking
into account all risk factors described
above. When there is uncertainty
about the status and amounts of imported organic ingredients, a prod-uct-specific transaction certificate
should be requested from the supplier’s certifier. The transaction certificate is a document created by the
certification agency of the supplier
that not only documents the organic
status of a producer or processor, but
also documents the organic status of a
certain batch of product.
The introduction of transaction
certificates by the European Union
for imported organic products was
triggered by several major cases of
fraud, especially in bulk products as
described earlier. The transaction certificate should state all information
regarding a certain shipment that can
