Aims : 

This policy establishes rules for recognition of organic management previous to first inspection, and minimum conversion period under NPOP, Govt. of India/and NOP and COS.

Background :

Although conversion periods are clearly defined by organic regulations, these regulations do not establish detailed criteria for recognizing organic management previous to the first inspection. In some cases, competition between certifiers may lead to a negative trend of decreasing standards in this respect. To avoid this, clear rules for inspectors and certification officers are required.

Normative framework :

NPOP Standards :

Section 3 :

3.1.1 Conversion Requirements

General Principles

Organic agriculture means a process of developing a viable and sustainable agro ecosystem. The time between the start of organic management and certification of crops and/or animal husbandry is known as the conversion period. The whole farm, including livestock, should be converted according to the standards over a period of three years.

Recommendations

Conversion may be accomplished over a period of time. A farm may be converted step by step but both crop production and all animal husbandry should be converted There should be a clear plan of how to proceed with the conversion. The certification programme should set standards for different farming systems so that they can be clearly separated in production as well as in documentation, and the standards should determine norms to prevent a mix up of input factors and products.

Standards:

3.1.1.1 :

The standards requirements shall be met during the conversion period. All the standards requirements shall be applied on the relevant aspects from the beginning of the conversion period itself.

3.1.1.2 :

If the whole farm is not converted, the certification programme shall ensure that the organic and conventional parts of the farm are separate and inspectable.

3.1.1.3 :

Before products from a farm/project can be certified as organic, inspection shall have been carried out during the conversion period. The start of the conversion period may be calculated from the date of application of the certification programme or from the date of last application of unapproved farm inputs provided it can demonstrate that standards requirements have been met from that date of implementation.

3.1.1.4 :

Simultaneous production of conventional, organic in conversion and/or organic crops or animal products which cannot be clearly distinguished from each other, will not be allowed.

3.1.1.5 :

To ensure a clear separation between organic and conventional production, a buffer zone or a natural barrier should be maintained. The certification programme shall ensure that the requirements are met.

3.1.1.6 :

A full conversion period is not required where de facto full standards requirements have been met for several years and where this can be verified through several means and sources. In such cases inspection shall be carried out with a reasonable time interval before the first harvest.

3.2.2  Duration of Conversion Period

General Principles

The establishment of an organic management system and building of soil fertility requires an interim period, the conversion period. The conversion period may not always be of sufficient duration to improve soil fertility and re-establish the balance of the ecosystem but it is the period in which all the actions required to reach these goals are started.

Recommendations

The duration of the conversion period must be adapted to :

• the past use of the land
• the ecological situation

Standards

3.2.2.1 :

Plant products produced can be certified organic when the national standards requirements have been met during a conversion period of at least two years before sowing or in the case of perennial crops other than grassland, at least three years (thirty-six months) before the first harvest of products. The accredited inspection and certification agency may decide in certain cases (such as idle use for two years or more) to extend or reduce the conversion period in the light of previous status of the land but the period must equal or exceed twelve months.

3.2.2.2 :

The conversion period can be extended by the certification programme depending on, e.g., past use of the land and environmental conditions.

3.2.2.3 :

The certification programme may allow plant products to be sold as “produce of organic agriculture in process of conversion” or a similar description during the conversion period of the farm.

3.2.2.4 :

For the calculation of inputs for feeding, the feed produced on the farm unit during the first year of organic management, may be classified as organic. This refers only to feed for animals which are themselves being reared within the farm unit and such feed may not be sold or otherwise marketed as organic. Feed produced on the farms in accordance with the national standards is to be preferred over conventionally grown / brought-in feeds.

3.3.2  Length of Conversion Period Animal husbabandry

General Principles

The establishment of organic animal husbandry requires an interim period, the conversion period.

Recommendations

The whole farm, including livestock, should be converted according to the standards. Conversion may be accomplished over a period of time. Replacement poultry should be brought onto the holding at the start of the production cycle.

Standards

3.3.2.1 :

Animal products may be sold as “product of organic agriculture” only after the farm or relevant part of it has been under conversion for at least twelve months and provided the organic animal production standards have been met for the appropriate time.

3.3.2.2 :

The certification programme shall specify the length of time by which the animal production standards shall be met. With regard to dairy and egg production, this period shall not be less than 30 days.

3.3.2.3 :

Animals present on the farm at the time of conversion may be sold for organic meat if the organic standards have been followed for 12 months.

NOP :

§ 205.202 Land requirements :

Any field or farm parcel from which harvested crops are intended to be sold, labelled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients)” must:
(a) Have been managed in accordance with the provisions of §§ 205.203 through 205.206
(b) Have had no prohibited substances, as listed in § 205.600, applied to it for a period of 3 years immediately preceding harvest of the crop

§ 205.103 Recordkeeping by certified operations :

(a) A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labelled, or represented as “100 percent organic,”  “organic,” or  “made with organic (specified ingredients).”
(b) Such records must:
(1) Be adapted to the particular business that the certified operation is conducting;
(2) Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited;
(3) Be maintained for not less than 5 years beyond their creation; and
(4) Be sufficient to demonstrate compliance with the Act and the  regulations in this part.

COS :

5.1.2

• The enterprise shall aim at a complete transition of its production. During the transition period, the enterprise can maintain, in addition to the production in transition, a non-organic system of production (split operation) that shall be entirely separate and identified separately, pending its incorporation into the overall transition process.
• The enterprise can be converted one unit at a time, and each converted unit shall respect the requirements of this standard. The exception to this norm, parallel production, is only allowed in the following cases: perennial crops (already planted), agricultural research facilities, production of seed, vegetative propagating materials and transplants. The following special conditions shall be observed for parallel production:

a. The operator shall clearly demonstrate that the identity of the crops so produced can be maintained during their production, harvesting, storage, processing, packaging and marketing.
b. The operator shall maintain verifiable, accurate records of both non-organic and organic produce and product storage, transportation, processing and marketing.

5.1.3  Buffer Zones

a. Buffer zones shall be at least 8 m wide.
b. Permanent hedgerows or plant windbreaks, artificial windbreaks, permanent roads or other adequate physical barriers may be used instead of buffer zones.

5.1.5 Crops grown in buffer zones shall be considered non-organically grown products whether they are used on the farm or not.

5.1.6 Production units shall not be alternated between organic and non-organic production methods.

Terms :

• Conversion : the period from last application of prohibited substances on land, to organic certification. Synonym: Transition.
• T1, T2, T3 : first, second, third year of transition (conversion)

Policy :

Conversion period under NOP and COS :

While NPOP allows reduction in conversion period based on the previous management and ecological situations, it requires a minimum of one year for cultivated lands. Even though NOP Final Rule does not mention the term “conversion” or “transition”, the above-mentioned paragraph 205.202 clearly establishes that no prohibited substances (referring especially to chemical fertilisers, pesticides, and sewage sludge) must have been applied on the respective plots during at least three years before harvest of organic products. Paragraph 205.103 says that previous management must be adequately documented. Thus, management previous to the first inspection can be recognised as “organic” only in case, that complete and updated farm diaries have been kept, and invoices for the purchase of farm inputs have been filed, for the period of at least three years. If this is not the case, the procedure established in 5.3 can be used.

COS :

This standard shall be fully applied on a production unit for at least 12 months before the first harvest of products. Substances prohibited by par. 1.4.1 and substances not in CAN/CGSB-32.311, Organic Production Systems —Permitted Substances Lists, shall not have been used for at least 36 months before the harvest of any organic crop.

Start of conversion period under NPOP Regulations :

In normal situations (without retroactive recognition of conversion period – see 5.3), conversion period starts with signing a certification contract with ADITI or with the first inspection, whereas the respective earlier date applies.
In case of farmer groups with internal control systems, the last internal inspection visit is considered as the starting point of the conversion period for the individual farmer.

Proofs for retroactive recognition of non-use of prohibited substances under NPOP and NOP regulations :

The inspector will assess, to which degree the farm meets the criteria listed below. He/she will assign marks, in order to allow a quantitative evaluation. To obtain retroactive recognition of non-use, at least 20 marks must be obtained. Evaluation by the inspector is only preliminary, since the certification officer makes the final decision. Inspectors must be adequately trained, to be able to assess plausibility and credibility of different proofs.

Please note that the NPOP-regulation requires that previous organic management “can be taken into consideration retroactively only under the condition that satisfactory proof has been furnished (…) that the conditions were met for a period of at least three years”.
This implies that if an operator fulfils the requirements for a period of less than 3 years he could only receive the certification status of “1st year in transition” as a result of the first inspection, because retroactive recognition cannot be granted at this moment. However, there is a possibility to “save” periods with favourable history less than three years: If the areas in question will be subject of the organic control system the period that has been passed under the supervision of the certification body will be added to the period with the favourable history. So in case one and a half year of favourable history had been proved and if subsequently the area has passed another one a half year under the control of ADITI, the area respectively the products from this area can be certified as organic (in condition all other requirements of the regulation are fulfilled as well).

Proof	Marks to be obtained (maximum)
Fallow land with typical vegetation 3 years and older (evidence on the field or photos)	20
General non-use of chemicals on the respective crop in the whole region	10 to 20
Evidence on the field for non-use of chemicals (abundant weeds, pests and/or diseases); in most cases, these evidences reflect only the current year	6 to 10
Confirmations by neighbours or field workers	2 to 4
Confirmations by state authorities	2 to 5
Confirmations by organic farm advisors or associations	5 to 10
Confirmations by local agrochemical sellers	2 to 4
Laboratory analysis of pesticide residues (usually reflect only the current season)	3 to 5
Laboratory analysis of soil nutrient availability	3 to 5
Own records showing purchase and/or application of organic inputs	4 to 8
Own records showing decline of yields after conversion to organic	5 to 10

Minimum requirements for retroactive recognition of conversion period under NPOP, besides non-use of prohibited substances :

Non-use of chemicals is not enough for qualifying a farm as “organic”. Organic farmers must have a good level of knowledge on standards and techniques, soil fertility management, and record keeping. Depending on their performance in these aspects, the procedure will be as follows:

Situation	Proofs on previous management	Knowledge, performance concerning soil fertiliy, crop rotation, record keeping etc.	Certificate	Organic marketing	Second inspection
A	Sufficient	No non-compliances	Can be issued	Can start	In case that organic marketing starts immediately, the second inspection should take place not later than 6 months after the first. Otherwise, the normal annual rhythm will be applied.
B	Sufficient	Minor non-compliances	ADITI issues a confirmation, announcing that certification is in process – or a certificate, which expires before the harvest.	Only possible after second inspection	Before the first products can be sold as “certified organic”
C	Sufficient	Substantial non-compliances	Only after a new inspection	Only possible after second inspection	Usually in the next growing season, only in exceptional cases during the same season

 

 

Retroactive recognition of new fields belonging to already certified farms :

In case of new fields belonging to already certified farms, the proofs for non-use of chemicals mentioned under ‘Proofs for retroactive recognition of non-use of prohibited substances under NPOP and NOP regulations’ are sufficient. The procedure described under ‘Minimum requirements for retroactive recognition of conversion period under NPOP, besides non-use of prohibited substances’ needs not to be followed.

Conversion period in group certification :

Please refer to ‘Perennials planted after beginning the conversion period’ of our Policy on Group Certification.

Conversion period for lands that meet the standards de facto :

NPOP (3.1.1.6.) allows reduction in conversion period for lands where de facto full standards have been met. Inspection can carried out with a reasonable time interval before harvest.

Perennials planted after beginning the conversion period :

We understand that conversion period for perennials are longer than for annuals, because the plants themselves might potentially be polluted with chemicals. This is not the case for annuals, which are planted after starting the conversion period, especially if organic planting stock is used. For this reason, in these situations, ADITI will handle the conversion period for perennials similar to that for annual crops: 24 months, plus a medium growth period of 4 months, i.e. a total of 28 months until harvest (instead of 36 months).