European Organic Certifiers Council
EOCC
EOCC Mission: Cooperating for reliability Overall Goal of EOCC: Ensure and enhance the reliability of control and certification activities and decisions linked to EU regulations related to organic production. EOCC´s key objectives: - harmonize the implementation and interpretation of current EU legislation on organic production methods. - pro-actively collaborates with responsible authorities and equivalent partners of the organic sector to support the continuous development of European organic legislation which allows more efficient and consistent controls and certifications.
ID: 755639413555-75
Lobbying Activity
Response to Modification of rules on organic trade and simplification
18 Nov 2025
The European Organic Certifiers Council (EOCC) gathering 74 Control Bodies and Control Authorities welcomes the European Commissions consultation in the frame of simplification of the regulatory framework for organic production. Please find enclosed the four main points for EOCC. EOCC is thankful for all efforts provided to achieve this important initiative.
Read full responseResponse to Roadmap towards Nature Credits
30 Sept 2025
The European Organic Certifiers Council gathers 74 Control Bodies and Control Authorities active in 165 countries worldwide. EOCC members control and certify according to EU organic standards: - In European Union: at least 180 000 operators and 6 million hectares; - In Third countries: at least 180 000 operators and 20 million hectares. EOCC welcomes the Roadmap towards Nature Credits and takes the opportunity given by the Commission to submit its views and contributions on the elements set out in this roadmap. EOCC noted that, according to the Communication, certification is considered as a foundation for Nature Credits. Indeed, certification is presented as a key mechanism to ensure that nature-positive actions are credible, high-quality and in line with predefined criteria or principles. Strict criteria and principles are required for certification to ensure transparency, to avoid conflicts of interest, and to safeguard against greenwashing or double counting. EOCC advocates for clear, relevant and verifiable requirements. Certification should align with existing EU standards and frameworks (e.g., organic farming scheme) to minimize administrative burden. EOCC has a long and deep experience in the organic farming scheme certification process, having participated actively to the revision of organic EU regulation (Regulation (UE) 2018/848 and its secondary acts) and its implementation in both Europe and Third countries. Finally, the Commission will set up expert groups and pilot projects to develop methodologies and governance frameworks for certification and nature credits, ensuring stakeholder engagement and international cooperation. EOCC is committed to support the expert groups, to share its experience of control and certification and to participate in the development of the certification process. For all these reasons, EOCC would be grateful to be consulted in the upcoming exchanges related to the control system for nature credits. We remain at your disposal for this purpose. Best Regards, Antoine Faure, EOCC President
Read full responseResponse to Import into the Union of high-risk organic and in-conversion products
11 Jul 2025
The European Organic Certifiers Council (EOCC), gathering 77 Control Bodies (CBs) and Control Authorities, would like to share its feedback on the public consultation related to Delegated Regulation (EU) 2021/1698 and possible change of art. 8 related to the List of high-risk third countries and high-risk products. This feedback is the result of an internal consultation and reflects the vision of EOCC members. The main proposal of this draft document is to establish this List not only on the basis of a selection made after major, critical or repetitive non-compliances affecting the integrity of organic or in-conversion products or production but also, as new elements, on the basis of the suspicion thereof. This proposal sets the frame of the methodology to fix the yearly criteria, without fixing the criteria as such. EOCC welcomes the fact that the details of the criteria are not fixed in the REG. This allows flexibility to adjust the needs to yearly challenges. Yet, OFIS INTC cases are, for the time being, taken into consideration as criteria to establish the List. Though, EOCC does not agree to take OFIS Cases as unique criteria to establish the List. EOCC pleads to consider only established cases of major, critical or repetitive Non-Compliance, according to CBs conclusion after their Official Investigation as one criteria and not suspicion. EOCC welcomes the fact that, in the current criteria, volumes of products are taken into consideration. For EOCC, it is important that established cases of Non-Compliance are reflected and related to the number of consignments imported as well as the volume of products imported. It is important that the incidence level is reflected. Therefore, pragmatically, EOCC would like: - The approach is not limited only to OFIS notification - the mention or the suspicion thereof to be withdrawn of the proposal. - The List to be established, after consultation of the sector main stakeholders, according to an incidence level (that is to say a ratio between established cases of major, critical or repetitive non-compliances versus number of consignments imported and volume of products imported). - To be involved in setting the criteria taken into consideration each year to establish the List. Moreover, EOCC would like to take this opportunity to kindly request Commission to reconsider CBs access to OFIS statistics (See as a reminder EOCC Letter of 2022 on this). EOCC remains available to be further involved in this process, Best Regards, EOCC
Read full responseMeeting with Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development)
15 May 2025 · The EOCC views the current discussions on simplification as a danger to the organic sector.
11 Jul 2024
EOCC is the European Organic Certifiers Council, representing 73 Control Bodies and Control Authorities. EOCC welcomes the principle of a derogation period and thanks the Commission to have taken into consideration the need for a period of coexistence of both schemes, equivalence and compliance, for the year 2025. EOCC calls for a derogation period lasting until 31.12.2025 (whole calendar year 2025). This will allow a good switch from equivalence to compliance and avoid unnecessary challenges and unjustified significant impacts for the operators (as already stated in several organisations contribution in the Have Your Say website) in an already very uncertain economic and geopolitical context. Pls see the attached file.
Read full responseResponse to Requirements for control bodies controlling operators in third countries for organic products sold in the EU
14 Jun 2023
The European Organic Certifiers Council (EOCC) gathering 73 Control Bodies and Control Authorities, has been active from 2017 to prepare the switch from equivalence to compliance regime. EOCC would like to remind that this is a collective process, involving Control Bodies (CBs), Accreditation Bodies (ABs) and the European Commission (EC). Before CBs' recognition for the purpose of compliance: EOCC acknowledges all efforts performed by CBs to prepare the implementation of the REG 2018/848 in Third Countries from 01.01.2025. In order to be active in Third Countries, CBs need: - to adapt their internal procedure (documentation, IT systems, training of inspectors, among others) according to REG 2018/848 and all related secondary legislation; - then to be accredited by ABs (Witness Audits, Office assessments) - then to apply for recognition by EC (European Commission) by fulfilling a technical dossier with ABs reports in the dedicated OFIS tool. For CBs already recognised for the purpose of equivalence, Witness audits performed during the two last years (included in the last accreditation cycle of 4 years) can be taken into consideration. EOCC takes good note of this current proposal to extend from the current 2 last years to the 3 last years the Witness audits that can be considered to be inserted in the technical dosser for the CBs recognition for the purpose of compliance. EOCC welcomes this proposal for the CBs that did not apply yet for recognition. The effectiveness of this measure will depend on the date of publication of this text. After CBs' recognition for the purpose of compliance: This current proposal intends to create an intermediate cycle of two years after the date of CBs recognition, before the normal 4 years cycle of surveillance starts. For EOCC, as long as the witness audits have been done for each category of products in equivalence before the application for recognition in the last 2 or 3 years, it is feasible to perform the witness audits in compliance in the normal accreditation cycle, that is to say within 4 years. This current COM's proposal (implying high accreditation's costs concentrated in two years in place of four years) will have an economic impact on CBs active in Third Countries, in the first two years of their recognition, mostly between 2025 and 2027 or later, in a very unpredictable economic context. On this, EOCC would like to underline that the first CBs' recognition might not cover the entire current CB's geographical scope, implying uncertainty on CB's income during the first years of their recognition. Therefore, EOCC kindly asks the withdrawal of the proposal related to this intermediate cycle. Doing so, will remain the upcoming surveillance cycle of four years, already challenging compared to the current 5-years cycle. EOCC remains at disposal to further discuss this bilaterally.
Read full response30 Aug 2022
The European Organic Certifiers Council (EOCC) gathering 71 Control Bodies, Control authorities and National associations of CBs would like to share its comments on the current draft regulation.
General Comments:
- On the annex itself, EOCC welcomes the efforts of simplification of the template, compared to the previous version. EOCC thinks that most of possibilities are covered, and the template is quite easy to be filled (even if more options could be added (e.g. in box 7)).
- EOCC requires more details on when and how to fill this template. There should be clear indications on the cases where the use of this template is necessary or not.
Is it only for established and confirmed contamination cases? If so, CBs shall then gather all these documents throughout the year, and at the end of the year, send it to the MS which will forward to the COM by March 31st?
So: how to deal with suspicion cases (Art 29.1.a): if CBs block for a defined period, because contamination seems to have occurred on previous stage of supply chain, is the template to be used, (and additional to OFIS?) and how to fill (Box 8: which measure of which stage of supply chain will be reported? blocking or if so, decertification?), it is unclear and parallel use of OFIS and the template will lead to double data of the same batch contaminated....
EOCC would welcome more instructions on how this practically shall work and on how the transmission of information shall take place.
Detailed comments :
1. Regarding the draft regulation:
a. In whereas 2, regarding Article 29.9, it says that COM should implement a computer system for MS to inform about "cases involving contamination with non-authorised products or substances in the previous year". CBs should know how and when COM is planning the implementation of this system and what will be the proposal for MS to gather the information from all the sources (CBs, Cas and official controls from the CpA or other governmental bodies) and be prepared for having all the information communicated at 31 of march. Still, CBs has no information on their role as the article 29.9 is addressed directly to MS and not to CBs but the information would come mainly from the CBs, and currently the information (even it´s not known from CBs) is that they would have to gather it from all 2022 cases. New information should be gathered from the CBs that would imply to check the whole case as for example the CN codes, if the contamination was pre-harvest or post-harvest, etc. If the system would be not ready for autumn 2022, there is no guarantee for a correct implementation of article 29.9.
b. Regarding article 1.1, Ms should inform to COMs about all the cases of Contaminations coming from article 29.1 including the reception of "substantiated information" and so, OFIS cases. From the whereas (3) and article 1.1, it is possible for MS to use the final documents to answer the OFIS cases (article 29.6 for notifying the cases of contaminations involved with this OFIS Cases, and so, the template would be used for the other official controls made through article 29.1 that would be the cases of findings in the inspections from CBs. It should be clear how the computer system would accept both kind of totally different datas if the aim is to finally gather information electronically to create the proposal from COM to the EP and Council on how to deal with the findings of non-authorized substances after 31.12.2025 (article 29.4)
2. Regarding Annex I of draft regulation:
c. Clear instructions are needed:
i. To fill the points of the template. Specially for points 1, 4, 5 including how to deal with cases of multi-findings of non-authorized substances. Examples would be welcomed.
ii. If some of the points, multichoice would be possible as for example in point 7 or 8.
d. In point 3, its proposed to include the item "litres".
e. In point 7, its proposed to include the option "use of contaminated machinery" as it is a usual cause.
Read full responseResponse to Update of the list of recognised third countries and control bodies for import of organic products
9 Aug 2022
EOCC gathering 71 CBs and CAs, would like to come back on the ‘Whereas 4,5, 6 and 7’ of this draft act. These ones are related to the COM proposal to remove CBs from Annex II of regulation (EU) 2021/2325, due to OFIS cases including contaminations with ETO on products from India. Hereby, EOCC would like to reiterate its position, published on 18.11.2021 and which has not received an answer at this date.
Positive Analysis does not end necessarily as a non-compliance
First, EOCC would like to emphasize that, from a regulatory point of view, a positive result showing the presence of non-authorised products and substances is not per se a non-compliance in regard to the EU organic regulation. It is not a non-compliance per se but a suspicion of non-compliance if indicating that production rules have not been complied with, that has to be further investigated by CBs. In the ETO cases on sesame seeds from India, we were informed that CBs have investigated. We were informed that according to their accreditation bodies, they have been proactive and took the appropriate measures towards the operators concerned.
CBs are shown as bearing sole and whole responsibility
The Organic Unit of DG AGRI considers that CBs failed in their responsibilities by not having detected the ETO issues on sesame seeds imported from India to European Union.
EOCC would like to underline that the control system of imported organic products is organized as such as it is not possible to reject the whole responsibility to CBs. Responsibility is the one of operators (that are the first responsible to be compliant with equivalent rules to the EU Organic Regulation). The responsibility is the one of Indian authorities that provided phytosanitary certificates mentioning that no fumigation occurred. If this would not have been the case, it would have created useful doubts and suspicions. The responsibility is shared with the European Competent Authorities that have namely cleared some consignments of organic products at points of entry of the European Union, not detecting the presence of ETO. For EOCC, it is not fair nor proportionate that these ETO / OFIS cases lead to single individual sanctions of CBs whereas the responsibility is collective.
EOCC was informed that its member CB involved took reactive and appropriate measures and since 01.01.2021, there were no new OFIS notifications on ETO detection on any Category D products, for which all the CBs have issued Certificates of Inspection (COI) in the year 2021. There is neither no ETO detection at destination countries for the consignments shipped after 1st January 2021. These are indicators for the effectiveness of the implementation of the preventive measures taken by the CBs.
EOCC considers that the COM proposal (specially the whereas) to remove the CBs from Annex II nearly one and a half year after the last ETO OFIS alert gives the impression that the ETO case is always in progress, when this is no more the case since early 2021. This also gives the impression that only the withdrawal will put an end to the non-compliant situation. For EOCC, this is not fair as it lets think that the whole responsibility is on CBs shoulders, whereas the responsibility is collective among the organic industry and all involved actors, and whereas this sanction does not take into consideration each CB’s specific situation. This collective delisting is not the adequate answer to the ETO cases as it will weakness the system instead of making it stronger.
EOCC proposal
Therefore, for all these reasons EOCC kindly asks the European Commission to rethink its approach, making it more proportionate and more appropriate. Concretely, EOCC is asking to take out the ‘Whereases 4, 5, 6 and 7’ of the draft text to be submitted to the vote and lift the withdrawal of its member CB, as it took appropriate measures according to their accreditation body.
EOCC remains available to further discuss this issue.
Read full responseResponse to Trade rules for organic production (implementing)
18 Nov 2021
The European Organic Certifiers Council (EOCC), gathering 69 CBs and CAs, would like to come back on the ‘Whereas 5’ of this draft act. This one is related to the COM proposal to remove five CBs from Annex III, due to OFIS cases of Ethylene Oxide (ETO) on sesame seeds from India.
Collective responsibility but CBs are shown as bearing sole and whole responsibility…
The Organic Unit of DG AGRI considers that CBs failed in their responsibilities by not having detected the ETO issues on sesame seeds imported from India to European Union.
EOCC would like to underline that the control system of imported organic products is organized as such as it is not possible to reject the whole responsibility to single CBs. Responsibility is the one of operators and, for them, measures have been taken by the CBs. The responsibility is the one of Indian Authorities, that provided phytosanitary certificates mentioning that no fumigation occurred. If it would not have been the case, this would have created useful doubts and suspicions. The responsibility is the ones of the Indian CBs. The responsibility is shared with the European Competent Authorities that have namely cleared some consignments of organic products at points of entry of the European Union, not detecting neither the presence of ETO. For EOCC, it is not fair that these OFIS cases lead to single individual sanctions of CBs whereas the responsibility is collective.
According to the information that EOCC has gathered, involved CBs took reactive and appropriate measures and since 01.01.2021, there are no new OFIS notification on ETO detection on any Category A products, for which all the five CBs have issued Certificates of Inspection (COI) in the year 2021. There is neither no ETO detection at destination countries for the consignments shipped after 1st January 2021. These are indicators for the effectiveness of the implementation of the preventive measures taken by the five CBs. The CBs measures haven been notified to the Indian National Authority APEDA, that should have been in contact with the DG AGRI.
EOCC considers that the COM proposal to remove collectively the five CBs from Annex III is not fair as it lets think that the whole responsibility is on CBs shoulders, whereas the responsibility is collective among the organic industry and all involved actors, and whereas this sanction does not take into consideration each CB’s specific situation. This collective delisting is not the adequate answer to the ETO crisis, and EOCC is ready to further discuss with DG AGRI about the lessons to learn from these OFIS cases and to define the necessary measures to prevent further occurrence of such contaminations.
According to EOCC, lessons to learn is that CBs should get an access to all OFIS alerts. It is not the case for the time being. This prevents CBs to have a precious source of information in the frame of their risk analyses. An anonymized request module would be welcome and EOCC could bring user feedback to develop such tool.
There is also a need for clarification on distinction ‘processed/non-processed products’. EOCC is ready to discuss the distinction ‘husked vs dehulled products’ (the first one considered by COM as a non-processed product, the second one as a processed product...) and more generally to further discuss this broader issue of distinction ‘processed/non-processed products’ with involved Units of DG AGRI and DG SANTE.
Therefore, for all these reasons and given the short deadline as the vote on the draft IA will take place from 22.11 on a written form, EOCC kindly asks the European Commission to take out the ‘Whereas 5’ of the draft text to be submitted to the vote and to consider this issue as a separate one. COM will have further opportunity to decide on this issue, with updated pieces of information from the five CBs, that might not have been brought to COM’s knowledge by APEDA before the launch of this Feedback mechanism.
Read full responseResponse to Organics - Details on records to be kept and declarations to be communicated by operators
1 Oct 2021
Regarding Article 1 of the draft regulation, the European Organic Certifiers Council (EOCC), gathering 67 Control Bodies and Control Authorities, would like to resume its position on issuance of certificates for operators through TRACES:
o EOCC is not supportive on issuance of certificates through TRACES.
o CBs/CAs prefer to issue the certificates for Operators through their own IT internal system.
o CBs/CAs currently work on this to update their IT internal system and will be ready to issue the new certificate from 01.01.2022 from their own IT own systems.
o Should TRACES system be imposed by COM to CBs/CAs, then EOCC asks for at minimum a one-year transition period on this. EOCC would like to get the guarantee that, by the end of the transition period, will be possible:
- The automatic datas upload to TRACES, in order to avoid to CBs to enter manually all entries into TRACES;
- The datas security related to the automatic data upload;
- The E-Seal.
Please find enclosed more details on EOCC position in the attached EOCC letter of September 13, 2021.
Read full response12 Jul 2021
In the frame of the Feedback mechanism on IADAs on Trade Rules, the European Organic Certifiers Council (EOCC), gathering 65 Control Bodies (CBs), Control Authorities and national association of Control Bodies, welcomes these acts and would like to share :
- the comments directly implemented in the enclosed documents, through track changes. Sorry for the inconvenience as the attachments were not to be downloaded on this Website of the Commission, though the format is pdf. Attachments have been sent directly to the Organic Team.
- as well as the following additional remarks:
- Imports out of the scope of the COI
The current regulation defines in detail the procedure for business-to-business transactions. However, our society is moving towards a more digitalized system. What about companies based in third countries that may be selling through e-commerce directly to final consumer? There are more and more companies located in Third Countries, with products stored in Third Countries, that send packages of organic products to the individual final consumers. These products are not submitted to the import requirements nor to custom duty. EOCC is well aware that this situation is not unique to the organic sector, goes far beyond the organic sector and implies the commitment, at COM level, of other DG than DG AGRI. However, we think that this issue should be discussed and addressed with the sector in the coming months.
- Art. 4.1 of DA
A COI shall be issued before the consignment leaves the third country of export or of origin.
According to Art. 5.3, there is a flexibility of 10 days to change the information related to Box 13, 16, 17.
There are some events where it happens that other pieces information, not related to Box 13, 16, 17, must be changed. This is, for example, in the case of
- need to enter a financial intermediary that was not identified before the leaving of consignment: Box 6
- change of BCP (Box 10): A shipment arrives to another Point of Entry as initially planned.
In these cases, there is no other option than to replace the COI. In case a CB replaces the COI in order to amend other information (than Box 13, 16 or 17), this will mention a date after the leaving of the consignment. Hence, as per regulation, it would not be in compliance.
EOCC would welcome an official procedure for such events when some pieces of information need to be replaced in the COI.
EOCC hopes that these remarks could be taken into account during the feedback mechanism and stays available for any further exchanges on these points.
Read full responseResponse to The certificate of inspection and the official controls at the entry into the Union of organic products
12 Jul 2021
In the frame of the Feedback mechanism on IADAs on Trade Rules, the European Organic Certifiers Council (EOCC), gathering 65 Control Bodies (CBs), Control Authorities and national association of Control Bodies, welcomes these acts and would like to share :
- the comments directly implemented in the enclosed documents, through track changes. Sorry for the inconvenience as the attachments were not to be downloaded on this Website of the Commission, though the format is pdf. Attachments have been sent directly to the Organic Team.
- as well as the following additional remarks:
- Imports out of the scope of the COI
The current regulation defines in detail the procedure for business-to-business transactions. However, our society is moving towards a more digitalized system. What about companies based in third countries that may be selling through e-commerce directly to final consumer? There are more and more companies located in Third Countries, with products stored in Third Countries, that send packages of organic products to the individual final consumers. These products are not submitted to the import requirements nor to custom duty. EOCC is well aware that this situation is not unique to the organic sector, goes far beyond the organic sector and implies the commitment, at COM level, of other DG than DG AGRI. However, we think that this issue should be discussed and addressed with the sector in the coming months.
- Art. 4.1 of DA
A COI shall be issued before the consignment leaves the third country of export or of origin.
According to Art. 5.3, there is a flexibility of 10 days to change the information related to Box 13, 16, 17.
There are some events where it happens that other pieces information, not related to Box 13, 16, 17, must be changed. This is, for example, in the case of
- need to enter a financial intermediary that was not identified before the leaving of consignment: Box 6
- change of BCP (Box 10): A shipment arrives to another Point of Entry as initially planned.
In these cases, there is no other option than to replace the COI. In case a CB replaces the COI in order to amend other information (than Box 13, 16 or 17), this will mention a date after the leaving of the consignment. Hence, as per regulation, it would not be in compliance.
EOCC would welcome an official procedure for such events when some pieces of information need to be replaced in the COI.
EOCC hopes that these remarks could be taken into account during the feedback mechanism and stays available for any further exchanges on these points.
Read full responseResponse to Organic food: certificate for operators located in third countries and list of control authorities
9 Jun 2021
The European Organic Certifiers Council (EOCC), gathering 65 Control Bodies (CBs), Control Authorities and national association of Control Bodies, would like to share the following point of attention related to the Implementing Act ‘certificate for operators located outside the EU and list of control authorities & bodies’ and its annex.
EOCC would like to underline the importance of the following remaining points of concern:
- EOCC kindly asks to remove the mention of ‘exporter’. Exporters are operators. Certifiers will have to precise the activity of the operator in Box 5 of the model of certificate (one of these activities is ‘export’). Therefore, there is no need to mention ‘exporter’ besides ‘operator’ in the rest of the text.
- EOCC kindly requests any IT development allowing CBs/CAs to download datas from their internal system to the TRACES system for the purpose of issuance of the certificate, to avoid any double entry and related dedicated time.
- Listing the products in detail in the compulsory part of the certificate should not be a requirement:
• Directory of products is in the optional part in the model of certificate of Operators in European Union. The directory of products should be removed from the mandatory part and remain in the optional part in the model of certificate of operators in Third Countries.
• In EU regulation 2018/848 the aim of the certificate, which is an official certificate within the meaning of the official control regulation (Cf. Article 3.27 2017/625), is to attest that the notified activities of an operator meet the requirements of this regulation (Cf. Annex VI, Article 35.1.c, Preamble 83).
• The documents aiming to attest that the product meets the requirements regulation are:
o the organic export certificate (Cf. Article 44.2) and the certificate of inspection (Cf. Article 45.1.b.iii), issued by the certification Body (not the master certificate of Annex VI)
o the documents issued by the operator (official attestation)
• In Third Country, the certificate of Operator is not the single certificate. For each consignment, a Certificate of Inspection (COI) shall be issued through TRACES.
• The COI provides more precision on the products certified.
EOCC hopes that these remarks could be taken into account during the feedback mechanism and stays available for any further exchanges on these points.
Read full responseResponse to Organic food: control authorities and control bodies
21 May 2021
The European Organic Certifiers Council (EOCC), gathering 65 Control Bodies (CBs), Control Authorities and national association of Control Bodies, was pleased to be consulted and involved in the preparation phase of this Delegated Act and Annex. EOCC is thankful that some of its previous remarks have been taken into account for the different versions of this Delegated Act and its annex.
EOCC would like to underline the importance of the three following remaining points of concern:
- EOCC kindly asks to reconsider the 4 years cycle and to adopt a 5 years cycle for the supervision cycle (Article 3.4.a.b.c). It is more coherent to set a 5 years-cycle as national supervision cycle and accreditation cycle (according to ISO/IEC 17011) in EU Member States and Third Countries are of 5 years.
Should the proposal remained unchanged, please note that a 4 years-cycle (rather that a 5 years-cycle requested by EOCC) implies an increase of 20% of witness Audits for CBs. CBs as well as Accreditation Bodies will have to mobilize more human resources, implying financial consequences for them and therefore for certified operators.
- For a CB recognized for the purpose of equivalence, witness audits carried out in the 2 last years can be taken into account (Annex 1.B.3.a) in the technical dossier provided for the recognition for the purpose of compliance. EOCC kindly asks to consider the witness audits of the last 5 years.
As the current cycle is 5 years, some products categories have been witnessed at the beginning of the cycle (therefore earlier than the last 2 years). This means that, for these very categories, new witness audits should be performed. They would represent more than the half of witness audits to be performed before CBs submit their application for recognition on the purpose of compliance (March 2022). This is not technically possible.
Therefore, EOCC kindly asks to take into account the Witness audits of the last 5 years, in order to make effective the lighter measures for CBs already recognized for the purpose of equivalence.
- one additional Witness Audit shall be carried out for every 10 Third Countries (Article 3.4.c.ii)
As an example, this would imply for a CB covering 50 countries, 5 additional Witness audits.
According to the current Annex IV of REG 1235/2008, more than the half of the CBs have an activity in at least 10 Third Countries.
This criteria is too strict and will have an impact on small and medium-size CBs as well.
EOCC proposal would be one additional witness audit to be carried out for every 20 Third Countries. This would represent a good compromise between the objective of supervision and the size of CBs.
This being said, EOCC thinks that the objective would be better achieved by eliminating a quota for witness audits, but referring to results of previous CB evaluations asking for an increased frequency in case of significant nonconformities. Finally, in the case a volumetric approach would be maintain EOCC thinks that more criterias than the unique criteria of number of Third Countries is better. Volumetric criterias would be more relevant if a proportionality of at least the following indicators could be taken into account:
• Number of Third Country where the CB is active
• Number of Operators certified
• Volume of products exported to the European Union
EOCC hopes that these remarks could be taken into account during the feedback mechanism and stays available for any further exchanges on these points.
Read full response27 Nov 2020
EOCC is the European Organic Certifiers Council, gathering 63 Control Bodies, Control Authorities and Association of Control Bodies.
EOCC would like to raise awareness on the article 9 titled “Official controls” of this delegated act on organic heterogeneous material.
A part of the official controls relates to general regulation on seeds and other plant reproductive material. This require a specific competence already mastered and applied by the competent authorities (other than for organic farming) in charge of conventional seeds and other plant reproductive material. The control of the characteristics of heterogeneous seeds should be delegated to existing national bodies already in charge of control of seeds for registration in the national catalogue (for example GNIS in France) and not the delegated body for organic farming official controls.
Furthermore there is a lack of definitions, so it remains unclear, how (methods) and how long (time) organic breeding and production must be performed to qualify a plant grouping as "organic heterogenius material.
Read full responseResponse to Control rules in organic production
26 Aug 2020
EOCC, the European Organic Certifiers Council, gathering 61 members (Control Bodies, Control Authorities and Association of Control Bodies), shares its comments, through track changes, on the document.
Read full responseResponse to Control rules in organic production
26 Aug 2020
EOCC shares its feedback on the text of the draft Implementing Act. See attached file.
Read full responseResponse to Control rules in organic production
26 Aug 2020
EOCC, the European Organic Certifiers Council, gathering 61 members (Control Bodies, Control Authorities and Association of CBs), shares its feedback, through track changes, on this document.
Read full response