EU audit finds ‘many weaknesses’ in Indian organic products certification

A review from the European Union (EU) found “many weaknesses” in certification of Indian organic products for export to the EU, including farmers who are part of Organic Producer Groups (PGs) who know nothing about organic farming.

An audit, conducted by the Directorate-General for Health and Food Safety of the European Union during the period from 14 to 25 November in 2022, revealed weaknesses in supervision and the implementation of controls at various levels.

The audit team found “gross violations” against the National Organic Production Program (NPOP) by 26 PGs. Violations included very poor implementation or non-implementation of the NPOP and farmers who knew nothing about organic farming. “In many cases, farmers didn’t even know about PGs or their Internal Control System (ICS). They used unauthorized substances and/or chemical fertilizers.

Inspector crap

In many cases, the Evaluation Committee had problems locating executive directors, which did not have an office at certain addresses. In one case, a farmer had a large pile of various plastics, partially burned in the middle of an organic field. The audit noted that “While this was recorded as a non-compliance, the inspector did not notice an unburned plastic jug on top of the pile containing chlorothalonil (a non-systemic fungicide), not permitted for organic production.”

In another case, in a field where wheat had just been sown after the rice crop had been harvested, the inspector overlooked a bag containing hybrid sorghum seeds and a plastic bottle containing monocrotophos (an organophosphate insecticide).

However, he later noticed several bags that contained Acetamiprid (a neonicotinoid insecticide) and Tricyclazole (a fungicide used to control rice blast disease), respectively, which were located very prominently in the same field.

High degree of non-compliance

Despite this, the inspector did not check their suitability for use on crops grown in the inspected fields or adjacent fields. He did not even mention the details in the inspection report nor the place where the containers were found.

“The most significant weaknesses are that recent unannounced controls by APEDA as well as the audit team’s own findings show a high degree of non-compliance with the NPOP in producer groups and poor quality of inspections,” said the audit report.

The report said the structure and organization of the control system remains the same as it was during the 2015 audit.

The EU audit was also carried out on the Agricultural and Processed Food Export Development Authority (APEDA), which is the coordinator in the implementation of the National Organic Production Program (NPOP). APEDA also acts as the secretariat for the national accreditation body that gives a nod to the bodies that certify and guarantee organic production.

Not following up

“The critical findings reveal a systemic failure in controls implemented by certification bodies in PGs and significant shortcomings in previous oversight conducted by APEDA,” the report said.

In terms of follow-up after the findings, the audit team acknowledged that APEDA took “some immediate action” to prevent non-compliant products from being certified.

However, in the case of four Certification Bodies (CBs), no further follow-up action was taken – an indication of the continuing deficiencies in APEDA’s oversight and enforcement.

The report found fault with a common practice for PGs to delegate internal inspection and training tasks to a different legal entity called a “delegate,” usually a processor, exporter, or merchant who purchases PG-approved products.

“The commissioner does not necessarily have to be accredited by the same CB as the PG. This was the case for two PGs visited by the audit team who did not operate their own ICS. The internal inspectors were employed or paid by the commissioners.

“unauthorized delegates”

The audit team found that the commissioners were not necessarily certified according to the category for which they were supposed to bring their expertise (inspection/training). It said that this could hinder the effectiveness of internal controls.

Serious non-compliance among central banks was systematically found during unannounced inspections, and in many cases, no action was taken against them, the report said.

In recent years, the frequency of central bank supervision audits has not met the requirements of the NPOP. Furthermore, the scope and focus of the audits were insufficient and ineffective.

The audit said one of the certification bodies does not have any documented procedures for risk assessment of operators, which is a violation of the NPOP.

EU DG Health and Food Safety conducted the audit to verify that the production rules applied in India are those of the National Organic Production Program (NPOP), which has been sent to the European Commission and recognized by the EU as equivalent for some products.

It was also verified that the control measures were applied consistently and effectively and to ensure that APEDA had strengthened its controls system in light of the high incidence of ethylene oxide contamination in various organic commodities, particularly sesame seeds.

Work on e-commerce opportunities

The audit team found that, in response to the EU findings on ethylene oxide (ETO) in sesame seeds, APEDA took appropriate action, listing six high-risk products (sesame seeds, ginger, amaranth seeds, psyllium husk powder, quinoa and flaxseed) . Many shipments from India have been rejected due to the presence of ETO in the shipments.

The report concluded that “while the production rules of the NPOP, recognized as equivalent by the European Commission, are applied, control measures recognized by the Commission as having equivalent effectiveness to those of the European Union are not applied consistently and effectively.”

Delhi-based trade analyst S Chandrasekaran said, “The NPOP is a good document that has been endorsed by the EU. The need of the hour is a sincere meditation on revamping the organic enforcement system. An unbiased approach will enable the system to reach the right decision on checks and balances.”

He said the urgent need is to conduct an efficient audit of CBs and APEDA to protect India’s indigenous organic products.