When the USDA ended the US-India Organic Recognition in early 2021, they granted an 18 month transition period. Now that this transition is complete (as of July of this year), you may be wondering what exactly is required when importing organic products from India. In this article, we explain which certifications are now needed and what documentation you must maintain (and request) to demonstrate compliance.
All certified organic operations in the US sourcing products or ingredients from India must ensure that the items are certified to the USDA’s National Organic Program (NOP). This means the entire supply chain must also have certification to the USDA organic regulations.
Further, they must be certified to the NOP by a certification agency that is directly accredited by the USDA. This means that NOP certifications issued based on an APEDA (Agricultural and Processed Food Products Export Development Authority in India) accreditation are no longer valid. If you aren’t sure if the operation is certified by a USDA accredited certification agency, you can look them up on the Organic Integrity Database.
Operations in India must also maintain compliance with all requirements set by the Government of India, which includes certification to their National Programme for Organic Production (NPOP), and obtaining TraceNet certificates for exports. This means that operations located in India which are selling to the US will likely need to be dual certified to both India’s NPOP and the USDA’s NOP regulations. India’s NPOP certification is overseen by APEDA, and scope certificates for NPOP will be issued by certification agencies accredited to this program by APEDA.
The documents that must be maintained by US operations receiving organic imports from India include:
- Current NOP Scope Certificates for the suppliers located in India. The certificates must:
- Be issued by a USDA accredited certification agency.
- List the organic products or ingredients being imported.
- NOP Import Certificates must accompany all shipments. This document is issued by the USDA accredited certification agency that certifies the exporting operation located in India.
- National Programme for Organic Production (NPOP) TraceNet certificates (sometimes referred to as “TC’s” or “Transaction Certificates”) issued by the APEDA accredited certifier of the exporter for each shipment. These are required by the Government of India for all Exports from India to be sold as organic.
Beyond the above mandatory items, keep in mind that additional documentation will need to be maintained to ensure compliance with the USDA regulations. For example, importers must also ensure that any labeled products they receive are compliant and that the labels have been approved by the appropriate accredited certification agency. Likewise, it is vital that importers maintain document traceability linking back to the last certified supplier (BOL’s, invoices, etc.), and keep track of any other documents required for entry into the US (such as customs and phytosanitary forms). These items must be made available for review by your certification agency upon request, such as during an on-site audit.
If you want to learn more about the certification and documentation requirements for importing organic products into the US from India, check out the following resources:
- OneCert Blog: How do you tell the difference between an APEDA NPOP certificate and a USDA NOP certificate?
- USDA – International Trade Policies: India, Updated July 13, 2022
- U.S. – India Organic Recognition: Transition Questions and Answers
- Instructions for Completing an NOP Import Certificate
- APEDA’s National Programme for Organic Production (NPOP)
- APEDA’s Trade Notice for the Issuance of Transaction Certificates for Export of Organic Products