Brief introduction to requirements for group certification
according to the NPOP, Govt. of India, the US National Organic Program (NOP), COS and ADITI standard interpretation

Group certification:

• Is a necessary tool to allow smallholders access to organic markets
• Requests a high level of commitment and knowledge by the organisation or certificate holder
• Is possible for crop production, animal husbandry, or beekeeping.

Normative framework:

• According to NPOP, the group certification system shall be based on an internal quality system and shall apply to groups, cooperatives, contract producers and small scale processing.
• According to NOP, farmers with less than 5,000 USD annual turnovers can sell organic products without certification; this, however, refers more to smallholders in the USA, who sell directly to consumers. These producers are not allowed to display the USDA-seal.
• The International Federation of Organic Agriculture Movements (IFOAM) organised several meetings on group certification, and then published a set of normative and training documents.
• ADITI, taking into account these different approaches, has worked out its own policy; the following is based on this interpretation.

What are smallholders:

• We take the definition of small holders according to NPOP, which states that the producers in the group must apply similar production systems and the farms should be in geographical proximity. Farms with land holding of 4 ha and above can also belong to a group but will have to be inspected annually by the external Inspection and Certification agency. The total area of such farms shall be less than 50% of the total area of the group.

What is a producer group:

• Producer groups can be cooperatives, associations, or similar organisations; but also processing or trade companies can organise their suppliers in a producer group.
• Producer groups must be located within the same geographical region, have the same kind of product and similar production systems.
• In case the group is spread over a large region, it has to be subdivided in smaller groups
• Group certification makes sense only for groups from 15 members on; nevertheless, also smaller groups should feel encouraged to set up their own internal control system, independently from the percentage of external control by the certifier.

Internal control:

• The group should have a legal status
• As a basic requirement, all producers have to be controlled at least twice per year by the internal inspectors.
• Internal inspectors must be adequately prepared for performing their job; we recommend training by our staff.
• Conflicts of interest must be avoided when selecting internal inspectors; nevertheless, we recognise that situations may exist, where consultants will have to do the internal inspections
• Internal inspections must be documented in reports, signed by the producer and the inspector; and the reports must be properly filed.
• Internal inspectors must dedicate enough time to each inspection.
• Reports must describe all relevant features of the operation, and must outline non-conformities.
• Results of internal control must be evaluated and summarized in the organic management plan and in the Internal Inspection Report Revision Spreadsheet.

Internal quality system (IQS) and approval:

• The group must have standard operating procedures (SOP), including, among others, registration of the farmers, remediation measures and sanctions for non conformities.
• The group should have an Internal Standard, which is a simplified and customised version of the NPOP/NOP.
• The internal regulation must be written in a local language, which is understandable for all group members.
• The group must have sufficient staff to operate the internal control system including but not limited to internal quality manager, internal inspectors, approval committee, field officers, purchase officers, processing officers depending on the size of the operations.
• An internal approval body must evaluate the reports, supervise the inspectors, pre-approve growers, and impose remediation measures.

External control:

The sampling plan for inspection shall be based on the inspector‘s perception of risk based on the following factors:

1. Size of holding
2. Number of the members in the group
3. Degree of similarity between the production system and crop system
4. Inter-mingling / contamination
5. Local hazards

• The number of producers controlled by the external inspector, is determined by the square root of the number of all growers, multiplied by a risk factor:

y = r x √x (y = producers controlled by our inspector, r = risk factor, x = number of all group members); the minimum is 10

• The risk factor “r” can vary between 1 and 4: groups with a low-input crop, good internal control system (ICS) and low rate of nonconformities, will have a low risk factor, and vice versa; example:

• The sample for external evaluation must, of course, be representative for the whole group; in big organisations, each subgroup‘s ICS has to be evaluated separately.

Records:

• The group must present a detailed organic management plan.
• Farmers must keep a minimum of records (see “brief information on crop production”)
• Records on purchased, stored, processed, and sold quantities must be kept at each step, from the producer to export or final sale.

Certification:

• The group can only be certified in case the ICS works properly; this includes, among others, that internal inspectors must detect non-conformities, and the approval body must react properly and implement the respective corrective actions.
• New producers can be included in the organic farmers list only after approval by the certifier.

Standard Inspection Program for Producer Groups According to the NPOP, Govt. of India, the US National Organic Program (NOP), COS and ADITI standard interpretation

As a minimum, the inspection of producer groups will cover the following aspects:

Review of the organic management plan and its implementation.

Physical inspection :

Visit to a representative number of farms (see ADITI policy on group certification), focussing on:

• Seeds or planting stock
• Soil fertility management and erosion control
• Fertilisers used
• Plant protection
• Crop rotation in case of annual crops
• Use of legumes
• Buffer zones
• Parallel production
• Conversion period
• On-farm records (farm diary, invoices for inputs, bookkeeping on sales)
• Labelling and traceability

During these farm visits, the inspector will carry along the respective internal control reports, and check, whether they are complete and correct.

Witness audit during a number of internal inspections, determined by the ADITI inspector.

Inspection visit to harvesting and storage rooms, eventual processing units, focus-sing on:

• adequate separation from non-certified products during storage, transport, processing, packing
• suitability of containers and tools
• labelling and traceability
• sources of post-harvest pollution

Records :

• Complete producers list, including name, code, location, area, etc.
• Regional map, highlighting locations of all farmers (or, in case of big organisations with several subgroups, at least location of these groups), wholesale points, storage rooms, and processing or packing units
• Flow chart, showing product flow from individual grower to export or other destination
• Internal inspection reports for all producers
• Internal regulation
• Records on farmers’ training and consultancy
• Contracts between farmers and organisation
• Invoices for inputs (seeds, fertilisers, plant protection products, etc.) purchased by the organisation; invoices or delivery notes for their sale to indi-vidual producers
• Records on purchase, storage, processing and sales at the different levels (wholesale points, processing units, warehouses, etc.)
• Waybills for transports
• Book keeping on all sales of farming products.

See also :

• ADITI policies on:

o Group certification
o Organic conversion period
o Buffer zones
o Traceability
o Pesticide residues and sampling frequency
o Crop rotation, legumes and cover crops
o Maximum field size
o Conventional poultry manure

• Brief information on group certification