Organic products procedure: Is there an example?

Purpose organic product procedure

Important for the production of organic food is the prevention of mixing organic ingredients with common ingredients. This means that the preparation must always take place separately. This is possible by producing organic products at a different time, on a separate machine or in a separate production area.

If organic products are made, they are made separately from regular production. In order to achieve this as well as possible, there are a number of specific methods with regard to planning, cleaning, storage and production. With this, we follow the requirements of organic.

Responsible	Team leader, Planning
Executive	Production production employee

Working method organic product

Planning

When planning the production order, the production of products with a claim is taken into account. Organic is one of the first to be produced. If this is not possible from a planning point of view, the line will be emptied before the start and cleaned.

Purchasing organic products

Purchasing is only allowed from suppliers who have a valid organic certificate. We store a copy of this in the supplier file. We also check at least annually whether our suppliers are still certified.

Receipt, identification and storage

An entrance check takes place in which it is checked:

• date of receipt
• name of supplier and his address details
• sales name of the product, it contains a reference to organic
• code/number of the inspection body
• traceable code (e.g. t.h.t)
• quantity of product received
• whether the packaging is closed (if applicable)

This check is digitally registered and the packing slip is signed off when the checkpoints are in order. In the administration, the registrations of the entrance control including the corresponding CMRs and invoices are kept for 2 years.

If during the entrance check it appears that something is not right or there is doubt about the biological status of the product, The organic certifying body will be informed.

Organic raw materials, semi-finished products and end products are provided with pink labels in the storage and process. Store as much as possible in a separate place in the warehouse.

Production

During the production of organic products, a color coding is used. This applies to production orders, recipe sheets, pallet sheets and labels. The pallet labels for organic products are **pink**.

In the name, the term organic or organic is called.

Production may only commence if it has been established that the machinery is clean and that no mixing can take place with non-organic products. Clean means sufficiently emptied and / or cleaned, so that no product residues are present. This check is recorded in the organic workplace cleaning control form.

If there is rework, only rework of the same organic product may take place and this must be stated on the production order. Traceability must be guaranteed. Rework only takes place in exceptional situations.

Actions in case of deviation organic products

If a deviation occurs, the production manager and quality department must be informed. Deviations in planning and production must be approved by the quality department. If necessary, the quality department informs certifying body about the deviation. In the event of a suspicion that a product that we have purchased, produced or prepared does not meet the requirements of organic production, we are obliged (according to article 91.1 of Regulation (EG) No. 889/2008) to inform the certifying body immediately. Doubts may exist about the bio-status of a product, for example as a result of residue finds or in case of suspicions of fraud. Only when the organic certifying body is convinced that the product is organic and all doubts have been removed, we can process, package or market the product again. In the meantime, The certifying body may require that the product not be marketed as organic.

Traceability

For traceability, please refer to the Reflex system that we use in our company. In it, we can find out the traceability of a batch. Our products must always be traceable. It is important in the tracing that each raw material is known exactly, when, in what quantity and in which products it was used. The sales must be demonstrably linked to the purchases.

Mass balance

A mass balance is an overview in which over a relatively short period (a week, month or quarter) the initial stock and the closing stock are stated per product and thereby all receipts and disposals (purchases and sales) of this product. The quantities in this statement must be in balance.

The organic certifying body has specific requirements for the mass balance and the mass balance is not the same as a trace test. The inspector of the organic certifying body checks the mass balance for a raw material and an end product. When choosing raw material and/or end product, make sure that these products are representative of our scope. Both mass balances must relate to the same period (week, month, quarter). Assume that the balance relates to multiple batches/ batches.

When checking the mass balance, the following documents shall also be checked:

• the receipts and purchases of these products with the freight documents received
• the purchase invoices
• the production data
• a disposal overview or sales overview of the products over the same period.

Mass balance Raw material:

• an overview in which the initial stock and the closing stock are stated over a clear period (one week, month or quarter)
• an overview in which the receipts of this raw material are stated
• an overview stating in which productions this raw material is processed
• In the mass balance the following calculation must be carried out: counted initial stock raw material received raw material
• used in production process (- residual flows) ≥ counted final stock  ingredient. You must be able to substantiate the mass balance with documents, e.g. purchase invoices, production statements, stock counts, delivery notes, sales invoices, etc.

Mass balance End product:

• an overview in which the initial stock and the closing stock are stated over a clear period (one week, month or quarter)
• an overview in which the receipts from productions are stated
• an overview of the sales/removals over a relatively short period (a week, month or quarter)

Product specifications

To produce organic products, we have to use organic ingredients. In addition to agricultural ingredients, we can use some permitted additives or excipients.

Requesting new products, modifying and deleting existing products and duplicating existing recipes via the customer area of the certifying agent. Only after approval of the product may the product be placed on the market as organic. After approval, the name of the product will appear on the appendix of the organic certificate.

The calculation of the organic share

Part of the organic certifying body’s product registration is the calculation of a product’s biological share. This checks whether the product consists of at least 95% organic agricultural ingredients. The calculation includes:

• Organic and non-organic agricultural ingredients.
• Biological additives and non-biological additives.
• Organic or non-organic yeast or yeast extract.

In the calculation does not count:

• Water
• Salt
• Processing aids
• Non-agricultural additives

We do specify these in the recipe.

Ingredients

Common ingredients
For a few ingredients, it has been determined that they are insufficiently bioavailable. These ingredients are listed in Annex IX to Regulation (EG) No. 889/2008. Only these ingredients can be used conventionally (non-organic) up to a maximum of 5%.

Genetically modified products

The use of genetically modified organisms (GMOs) is not permitted in organic products. For common ingredients, we need to prove that they were produced without the use of GMOs. We must request a GMO-free declaration from the suppliers and keep it in the records. A GMO-free declaration may not exceed one year of age. Usually this statement is part of the product specification.

Additives

Additives are additives to the product that we must mention on the label. For organic products, some additives are allowed. These are set out in Part A of Annex VIII to Regulation (EG) No. 889/2008. In this Annex, a distinction is made between:

• Food of plant origin (if at least 50% of the agricultural ingredients are vegetable)
• Food of animal origin (if at least 50% of the agricultural ingredients are animal)

Special conditions are included for some additives. We may only use the products under these conditions. Additives may in principle be used indefinitely, provided that permitted under the Additives Regulation. In the appendix are a number of additives provided with an astriks, which you must treat as common ingredients (so use a maximum of 5% in total).

Processing aids

Processing aids are additives to the product that disappear during the production process. We do not need to mention the processing aids as an ingredient on the label. For organic products, some processing aids are permitted. These are set out in Article 27 and Part B of Annex VIII to Regulation (EG) No. 889/2008. Special conditions are included for some excipients. We may only use the products under these conditions.

Other ingredients

In addition to the additives and processing aids, article 27 includes a number of other products that we may use:

• preparations based on micro-organisms and enzymes
• natural flavourings according to Article 16 of Regulation (EG) No. 1334/2008
• drinking water
• salt

The label

For the recognisability of organic products, we may, under certain conditions, use indications. Indications are all references to the organic production method on, among other things, label / product label. These are:

• The terms organic, organic, ecological, eco, organic
• the European organic quality mark (see the manual on the certifying party website for use)

The organic certification number must be printed on the packaging. We can choose to do it for traceability purposes. If necessary, see the label checker on the website to assess organic indications.

Risk analysis and annual internal audit

For each process, it was assessed which risks may arise. Risk analysis for organic products mainly relates to the contamination between conventional and organic ingredients/products (and not food safety items). The possible risks and the associated biological management points (GDPs) have been identified.

Every year we conduct an internal audit of the biological processes. The risk analysis is an important guideline for this internal audit. The other points in this procedure are also checked. General procedures and the basic conditions of the program, general and specific control measures, etc. are checked during regular internal audits and control rounds.

Organic quality mark

What format should the organic logo follow? Check out here the manual. The companies certified organic could download the logo in print quality via the certifying agent.