Changing Organic Certification Agencies
As a business grows, the needs of that business change and may require rethinking long-standing relationships. These may include changes in ownership, manufacturing, management or marketing. Your certification agency is a partner in the marketing of your product. Their name appears right on your packaging you hand to every customer. Also, since these agencies change over time, they may be the driving factor needing to change certification agencies.
When it becomes clear that the service, communication or support of your certification agency no longer meets the needs of a growing business, approaching a change should be well thought out. The USDA memo NOP 2038 covers a list of instructions and rules for making this change. It does not, however, clearly spell out the risks and pitfalls. For many companies, the internal changes or material costs far outweigh years of certification fees when making this decision.
The USDA does not allow companies to package product with a certification agency named on the product unless the company currently holds a certificate from the named agency. What is the trick to changing the packaging on exactly the same day you change certification agencies? In reality, most companies will hold dual certification for a period of time to enable using up packaging. This can be a troublesome time with two competing agencies inspecting and regulating your business.
One of the basic regulations of the USDA National Organic Program is to respect the decisions of other agencies. This means if one agency gives you a non-compliance, the other must respect and enforce it. When changing agencies, it is important to stay in good standing with the old agency until you are ready to voluntarily surrender their certification. They can stop you from becoming certified by the new agency or even suspend you from the program after receiving new certification.
Plan the change around the needs for packaging updates so that the new certification agency name can be incorporated into the designs. This process can take 3 to 6 months or more. If you have had a bad experience with renewing your certification, start planning the change now. Do not wait until the next renewal. Most agencies only give you 90 days notice about renewal. That will not be enough time to coordinate the change.
The National Organic Program regulations are guidelines for certification management and enforcement. There is often much room for interpretation by the certification agency about how to handle issues. If in question about a decision, seek out another agency or certification adviser for a second opinion. Certification agencies cannot give you advice but they can tell you what is allowed. I have seen an agency go to bat with the USDA against other certification agencies to bail clients out of a bind.
Do the research early and do it thoroughly to protect your organic certification status before trying to change certification agencies.