Numerous grower organizations and smallholders are
aware of the market for organic coffee. Because many of them do not use, or use
a minimum of agro-chemicals, conversion seems a logical option especially when
coffee prices are low. As well as the problem of possible oversupply, potential
producers should also carefully consider the costs of certification. They have
to assure themselves not only that their future output will be in accordance
with the rules of organic production, but also that the proposed inspection
system is in accordance with the regulations in the import markets that are to
be targeted.
To assist in this regard the organic sector has
developed an internal control system
(ICS) that provides a practical and cost-effective inspection option.
Generally, if a grower group has more than 30 members then it qualifies for an
ICS. Although an ICS can be quite burdensome, it is a means to reduce the costs
of inspection. Otherwise each individual member must be inspected every year,
which is extremely expensive, especially for larger groups with a geographically
far-flung membership. With a proper internal control system, only a random
sample of the total number of producers has to be inspected by an independent
certifying organization. Major ICS elements include:
- Internal standard, including
sanctions;
- Personnel;
- Infrastructure;
- Training and information;
- A 100% internal farm control at least once
a year;
- Monitoring of product flow.
The magnitude of the random sample to be taken by
the external inspection body under an ICS system is a major item of debate
within the European Union. Most competent authorities require a sample of 10% of
producers to be inspected annually, but some officials consider this number much
too small to offer the required consumer guarantees and want significant larger
samples. Others consider 10% far too high, especially for grower organizations
with large memberships and where access to the actual growing areas may be
difficult. As a rule of thumb most competent authorities however seem to accept
the square root method for external inspections, i.e. 100 members = 10
inspections, 400 members = 20 inspections and so forth. *
Note also that some
roasters submit random green coffee samples for chemical analysis to verify the
accuracy of the inspection and certification process...
* NB: Early 2007 the USDA
(United States Department of Agriculture) ruled however that 'using Internal
Inspection Systems as a proxy for on-site inspections of each production unit
(read smallholder) by the certifying agent is not permitted as it is not
consistent with the NOP'. The US proposal to withdraw acceptance of the ICS
arrangement has caused considerable agitation in the organic sector and is the
subject of discussion between the USDA and US Coffee Associations. It is our
understanding that further discussions will take place in the fall of 2007.
Until this matter is clarified the ICS arrangement remains valid for exports to
the US but growers and suppliers of organic coffee to the US are advised to
monitor all developments very carefully. See also Q&A 047 and 154 in the
Q&A Archive.
Updated 08/2007