Brief introduction to requirements for processing of organic food
according to the NPOP, Govt. of India, the US National Organic Program (NOP), Canadian Organic Standards (COS) and ADITI standard interpretation

1. Processing of organic food:

• Must assure traceability and transparency.
• Requires a good documentation system.
• Must not contaminate organic products through inappropriate post harvest handling.
• According to NPOP, COS, any handling and processing of organic products should be optimized to maintain the quality and integrity of the product and directed towards minimizing the development of pests and diseases.

2. Who needs to be certified as organic processor:

• All handlers who process, dry, freeze, clean, mix, pack, or label organic products after harvest, need to be certified.

3. Origin of organic raw materials:

• First of all (which may be self-evident for many), all post harvest handlers must understand that only certified organic raw materials can be processed to organic products.
• Only NPOP certified raw material can be used for products for the NPOP certified finished products, while raw materials for the US market must be NOP certified – so please always ask your supplier of raw materials for a copy of a valid certificate, issued according to the respective standard.

4. Separation:

• Some processors produce only organic, but most do both: organic and conventional.
• These latter handlers have to set up a good system for separating organic products from con-ventional ones: from the moment of reception of the raw material, through all steps of processing, storage rooms, etc., until sale. Separation must also be safeguarded between organic and transitional products, or products certified according to different standards (e.g. NPOP/NOP).
• The best separation, of course, is in space: have separate warehouses and processing lines for organic.
• However, this may often not be possible; in this case, you can separate in time: you process organic at different times on the same line as conventional; before processing organic, you have to clean the line.
• In case of continuous processes (e.g. mills), the operator must make sure that at the beginning of organic processing, a reasonable quantity of organic product is used for ―cleaning‖ the line, and sold as conventional.
• Where separate warehouses are not feasible, an adequate separation within the existing storage room may be sufficient: e.g. rows separated by a line on the floor, or separate shelves, properly labelled.

5. Documentation and labelling:

• An organic processor needs an organic management plan, or a chapter in his/her quality hand-book, which refers specifically to processing of organic food.
• Wherever parallel production of organic and conventional products takes place, bags, containers, boxes with organic products have to be labelled, at all steps through your facility.
• The operator has to keep and file supplier certificates, way bills, reception notes, processing protocols, storage books, and invoices; all these records have to refer to the organic condition of the product.
• Organic processors need a good book keeping system, allowing evaluating whether the quantity of purchased raw material is consistent with the quantity of finished product sold.
• Except for open raw material arriving directly from the field, only packed or sealed and labelled products must be accepted for organic processing, unlabelled products should be returned to the supplier.
• The NPOP-Regulation requires operators, who do not process organic “at regular times or on a fixed day”, to announce processing of organic products in advance to the inspection body.

6. Traceability:

• Everything mentioned under (3), (4), and (5), has to do with traceability, but since this is such a crucial point, here again: the organic market can develop only if the consumer trusts that the origin of what is on his/her plate, can be traced back to the organic farm.
• It is impossible to require the same level of traceability for such different processes as fresh fruit packers (where traceability back to the field level should be easy to achieve), dairies, oil mills, or noodle factories.
• Nevertheless, as a general rule, the highest possible level of traceability should be tried to achieve in every given situation.

7. Labelling of multi ingredient products:

According to NPOP, labelling shall convey clear and accurate information on the organic status of the product.

The following table gives an overview for labelling requirements for the different categories*:

NOP:

NPOP/EU:

COS:

8. Post harvest pest control, sanitation, polluting substances:

• The operator must make sure that the organic product at no moment comes into touch with polluting substances, such as fuels, pesticides, wood preservatives, detergents, molds etc.
• For pest control in stored products, only substances mentioned in appendix 2 (NPOP) or the Na-tional List (NOP) can be used.
• For cleaning, sanitation, and pest control of processing lines and rooms, the general rules of the re-spective food legislation apply.
• Beyond this, ADITI determines that after application of conventional pesticides in a processing facility, the waiting time until bringing organic products into the respective room has to be doubled, as compared to the time officially indicated for the respective substance; all surfaces which enter into contact with the organic product have to be rinsed with clear water.
• Although this is not a part of the abovementioned organic standards, ADITI requires that organic products are handled under appropriate hygienic conditions.
• As per COS; Pest management practices shall first involve the removal of pest habitat and food; second, the prevention of access and environmental management (light, temperature and atmosphere) to prevent pest intrusion and reproduction; and third, mechanical and physical methods (traps), lures and repellents listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists.

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

As a minimum, the inspection of organic processors will cover the following aspects:

Review of the organic management plan and its implementation.

Physical inspection :

Visit to all processing lines, places of raw material reception, storage rooms for raw material, semi-finished and finished products, packing units, etc., including subcontracted units, focussing on:

• Origin of organic raw materials
• Separation (in time or space) from non-certified products throughout the whole process, from product reception to final sale or delivery
• Use of processing aids and food additives
• Cleaning and pest control procedures
• GMO (genetically modified organisms)
• Prohibited methods (ionising radiation, etc.)
• Possible contact with prohibited or otherwise polluting substances
• Labelling and traceability

Records :

• Drawing of the unit, including eventual subcontracted units
• Flow chart, describing the process(es)
• Recipes
• Copies of valid certificates of all raw material providers
• List of raw material providers
• List of clients for organic products
• Records on all purchases of organic raw material
• Storage books
• Processing protocols
• Pest control protocols, list of products used for cleaning, disinfections, pest control
• Non-GMO declarations for processing aids or raw materials, which could potentially be produced with the help of GMO
• Records on outgoing organic products
• Bookkeeping
• Chapters on organic processing from quality management handbook (if existing)

See also :

• ADITI policies on:

o Traceability
o Pesticide residues and sampling frequency
o Minimum sanitary conditions
o Pest control in processing units

• Brief information on organic processing