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Organic Certification:
Why Do it and What Do You Need to Know?

By The Quality Assurance International Organization

The Quality Assurance International Organization (QAI) writes on everything the coffee roaster needs to know and do in order to obtain organic certification.

The organic market has been growing at a rate of 20-25% per year for the last decade, and the demand for certified organic specialty coffee has grown with it. Green Mountain Coffee Roasters, based in Waterbury, Vermont, started with a single line of organic coffee in 1997 and today carries over 35 different certified coffees. After they acquired Frontier Organic Coffee in 2001, organic products went from less than 2% of total coffee pounds sold to more than 10%. If you have considered jumping into the organic market, but aren’t sure if it’s right for you, here are some pointers about what it entails to get you started.

Now that the USDA’s National Organic Program (NOP) is up and running, consumers have increasing confidence in the integrity of the organic label. Anyone who sells more than $5,000 a year in organic products must become certified in order to legally use the organic label. The NOP sets the rules and requirements for organic certification, which is carried out by accredited certifying agents, who may be private businesses, non-profits, or state governments. There are currently 87 accredited certifiers, of which 34 are foreign entities. A current list of accredited certifiers is available on the NOP website (references at end).

Once you have decided to take the organic plunge you will need to get your sources lined up, and make sure your facilities, procedures, and records are organized to meet the requirements. You’ll also need to pay attention to how the product will be labeled, which must also conform to USDA’s rules.

Among the most important decisions to be made is choosing your certifier. Although it looks like there are lots of qualified organizations to choose from, not many of them are familiar with the issues involved in coffee roasting. Even fewer have the international expertise to assist with multiple countries of origin for raw product or export markets. Don’t forget that any organic coffee you bring into the U.S. will have to be certified by a USDA accredited certifier. And, if you want to sell coffee in the EU, Canada, Japan, and other international markets, the certifier should have accreditation from and/or partnerships with recognized agencies that will allow your product to be imported under those countries’ organic regulations.

Besides organic certification, many coffee lines are sporting “Shade Grown,” “Bird Friendly,” and “Fair Trade” labels. Bird Friendly, based on the Smithsonian Migratory Bird Center norms, requires that the product also qualify to be certified as organic. If your organic certifier can also offer certification services in any of these other realms, you can add additional value for a small extra investment. The entire Green Mountain Coffee Roasters line of organic coffees is certified Fair Trade by TransFair USA, an arrangement that has “greatly enhanced and strengthened the entire line,” according to Patty Vincent, coffee product manager at Green Mountain Coffee.

Although certifiers are barred from providing consulting services, your certifier must be able to give you all the information you need about what the rules say and what particular issues you have to address to be compliant. There are also a number of independent consultants, with background in organic inspection and certification, who may be available to go over your facility and procedures and help you get up to speed with your particular operation.

Organic Sources
First of all, make sure that all organic suppliers are or can be certified by a USDA accredited certifying body - you will need a current certificate on file to document this. If you are working with growers who are not certified organic but who could qualify, your certifier should be able to set them up with an appropriate local certifier, or else undertake their certification under your “umbrella.” Karen Cebreros of Elan Organic Coffees, who has sourced organic coffee for 14 years, comments that “certification of the coffee growing process has not only guaranteed authenticity of the source but has also greatly improved the quality of organic coffees and provided real benefits to growers.”

Because coffee roasting requires no additional ingredients or processing aids, the problem of finding acceptable sources and types of these inputs is minimized. The Swiss Water decaffeinating process similarly presents no problems with unacceptable materials. It is also getting easier to find certified organic flavorings. You can only use a non-organic flavoring in an organic product if the requisite organically produced and processed flavor is not “commercially available.” A place to check for potential organic suppliers is the Organic Trade Association (OTA) member directory.

If you do use a non-organic flavor you will not be able to call your product “100% organic,” but as long as at least 95% of the contents are organic you may use the “organic” label. You will also need to document that any non-organic ingredients were not produced through the use of genetically modified organisms (GMO’s), irradiation, or sewage sludge (otherwise known as the “big three”).

ISO, HACCP, and Other Quality Management Systems
If you have established certification under an ISO or HACCP program, your organic operations can easily be integrated into it. Whatever your quality management system may be, if you maintain: a quality manual, standard operating procedures for each phase of your process, good employee training (a real must!), a complaint handling procedure, and documentation that all these procedures are being followed - then you are already close to having what you need to pass an organic inspection. Says Jim Cannell of Jim’s Organic Coffee: “We feel that having a third-party inspection of our quality control process makes us more conscious of how well our own system works.”

Sanitation and Pest Control
One key to protecting the integrity of your organic product is care in preventing any possible contact with prohibited materials such as pesticides and cleaning agents.

Make sure that your pest control contractor is aware of your organic operation, and that you have written pest control procedures, maps of pest control stations, and logs showing all monitoring and pest control activities. Coffee roasters rarely need pesticides within the facility, but if that is ever necessary, be prepared to justify it and ensure that any organic products in storage or inventory are protected from contact by the material used.

Any time sanitizers are used on food contact surfaces it is advisable to double or triple rinse before running an organic line. Employees should check off a log to document where and when this is done.

Product Separation
The second key to protecting organic integrity is to prevent any possibility of commingling organic products with their conventional counterparts. This means that all equipment and lines should be completely free of conventional coffee before the organic product goes through them. If this isn’t feasible you can also purge the equipment, such as a grinder, with organic coffee that would then be diverted to the conventional product stream. Running organic lines at the start of a production cycle (i.e., after complete cleanout and sanitation of equipment and lines) is the best way to ensure that organic products cannot be accidentally commingled with conventional coffee.

The other critical ingredient in good product separation is clear signage (which should include tracking lot codes) on bags, pallets, totes, and other containers. A distinctive tag color that identifies the product as organic is also helpful. Separate organic storage areas and dedicated organic bins and hoppers, while ideal, are not essential if identifying tags are clear and equipment is thoroughly cleaned before the organic line is run.

Labeling
Do you want it to be 100% organic? Is the USDA seal interesting to you? Any non-organic ingredients or processing aids, even approved non-agricultural ingredients (such as the carriers in a flavoring), exclude a product from making the 100% claim. You are permitted to use the USDA seal and your certifier’s seal or logo on the Principal Display Panel (PDP), as long as you follow the specific requirements about size and colors of print and images. All organic ingredients and the certifier of the finished product must be identified on the information panel. Your certifier should review mock-ups of your labels before they are printed, to make sure that they are fully compliant with the NOP requirements.

Record Keeping and Audit Trails
Good record keeping is critical to any form of certification, including organic and other eco-labeling or fair trade schemes; document review occupies a major part of most organic inspections. “Organic certification is a simple process involving procedures which anyone in food processing should already be following as part of their commodity tracking system,” says Jim Cannell.

All final products bearing an organic label must be traceable from the packaged product that you ship to your customers through each transformation (packaging, grinding, blending, flavoring, roasting, cleaning, receiving of raw ingredients). It is essential to maintain a verifiable audit trail, based on lot codes that connect the final product to its component ingredients, including documentation of sanitation and clean out procedures as well as organic certificates for the raw ingredients. Many companies already do this as a matter of course, and regularly undertake mock recalls to ensure that the system is working as it should. Your records must also allow an inspector to compare quantities of organic finished products sold and in inventory with quantities of raw ingredients received. Records pertaining to organic products must be maintained for at least five years.

Certification and Inspection Process
Once you have developed your organic coffee plan and chosen a certification agent, you will undergo a process that is clearly laid out under the NOP: when you apply for certification you will be asked to complete an Organic System or Compliance Plan, including how your operation adheres to each of the relevant sections of the regulations. The certifier will review this information, and will let you know if there are any problems you need to correct before an inspection date is set.

A qualified inspector is then assigned to you, who will arrange a mutually convenient time to tour the plant and review your documents. Someone knowledgeable about the operation must be available for the inspection. The inspector will go over all the issues and concerns she or he observes and provide you with a copy during the exit interview.

The certifier then reviews all the information you submitted plus the inspection documents. You may be asked for additional information, such as copies of labels, at this time. If you are approved, you will receive a certificate that lists all the types of products covered, along with a letter outlining any problems you will need to correct. If there are major problems, such as lack of certification documents for raw ingredients, these must be corrected before a certificate is issued.

If you are turned down you can apply to a different certifier, but you will have to demonstrate that the issues identified by the first certifier have been corrected. You can also appeal any adverse decisions directly to the NOP.

Once you have been certified you will need to remain in compliance and update your Organic Compliance Plan each year. There will be another inspection as part of your annual monitoring requirement, at which time you will need to show how you have corrected any problems identified the previous year. Certification remains in effect until it is either voluntarily withdrawn or it is revoked or suspended, which requires action by the NOP and gives an opportunity to appeal.

The cost of certification can vary significantly, depending on the certifier. Some charge according to the quantity of organic product sold or gross sales income. Others set fees based on the cost of providing certification services. State programs tend to charge less, but may not be able to provide the level of service offered by private certifiers. You should be able to get an estimate of the total cost of certifying your operation before you submit an application.

All this may seem daunting, but the effort can prove to be worthwhile in terms of improving your own internal quality management system as well as your bottom line. Patty Vincent enthusiastically testifies that the effort has paid off for Green Mountain, saying that, “our certifier has been grooming us up for quite some time…it has not been that painful for us.” Beyond this, by participating in the organic market you will also be helping improve the social and environmental bottom line that matters to increasing numbers of consumers today.

About Quality Assurance International: QAI is a global leader in organic certification services. With offices in the U.S., Canada and Japan, and operations in Latin America, QAI verifies organic and other claims for more than 2,700 client locations. Clients include agricultural producers, contract packing operations, primary manufacturers, trader-distributors and retailers, among others. QAI’s certification programs are designed to verify compliance at every link of the product handling chain. This assures the consumer that product integrity is preserved in the marketplace.

References:



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