A European Union (EU) audit has found “many weaknesses” in the certification of Indian organic products for exports to the EU, including farmers who are part of organic producer groups (PGs) knowing nothing about organic farming.

An audit, carried out by the EU’s DG Health and Food Safety during November 14-25 in 2022, found the weaknesses in the supervision and implementation of the controls at various levels. 

The audit team found “severe infringements” against the National Programme on Organic Production (NPOP) by 26 PGs. The violations included very poor or no implementation of the NPOP and farmers knowing nothing about organic farming. “In many cases, farmers did not even know about their PGs or their internal control system (ICS). They applied unauthorised substances and/or chemical fertilizers,” it said.

Inspector’s folly

In many cases, the evaluation committee faced problems locating the PGs, which had no office at given addresses. In one case, a farmer had a large pile of various plastic materials, partly burned in the middle of an organic field. “While this was recorded as a non-compliance, the inspector did not notice an unburned plastic jug on the top of the pile that had contained Chlorothalonil (a non-systemic fungicide), not allowed for organic production,” the audit pointed out. 

In another case, on a field where wheat had just been sown after the harvest of a rice crop, a sachet containing hybrid sorghum seed and a plastic bottle with Monocrotophos (an organophosphate insecticide) were overlooked by the inspector. 

He, however, subsequently noticed several sachets that had contained Acetamiprid (a neonicotinoid insecticide) and Tricyclazole (a fungicide used for control of rice blast disease), respectively, which were very prominently located in the same field.

High degree of non-compliance

Despite this, the inspector did not investigate their relevance for use in the crops that had been grown in the inspected field or the neighbouring fields. He did not even note the details in the inspection report nor the location where the containers were found.  

“The most significant among the weaknesses is 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 at producer groups and poor quality of inspections,” a report of the audit said.

The report said the structure and organisation of the control system continues to remain as it was during a 2015 audit.

The EU audit was also carried out on the Agricultural and Processed Food Products Export Development Authority (APEDA), which is the coordinator in implementing the National Programme on Organic Production (NPOP). APEDA also acts as the secretariat of the National Accreditation Body which gives nod to bodies that certify and guarantee organic production.  

Lack of follow-up

“The critical findings reveal a systemic failure of the controls carried out by certification bodies at PGs and significant deficiencies in the past supervision carried out by APEDA,” the report said. 

Regarding the follow-up after the findings, the audit team acknowledged that APEDA took “some immediate action” to prevent certification of non-compliant products. 

However, in the case of four certification bodies (CBs) no further follow-up action was taken — an indication of continued deficiencies in APEDA’s supervision and enforcement. 

The report found fault with a common practice followed by PGs of delegating internal inspections tasks and training to a different legal entity called “mandator”, generally a processor, exporter or trader who buys the certified products from the PG. 

“The mandator is not necessarily certified by the same CB as the PG. This was the case for the two PGs visited by the audit team that did not operate their own ICS. The internal inspectors were employees of, or paid for, by the mandators,” it said. 

‘Uncertified mandators’

The audit team found that the mandators were not necessarily certified as per the category for which they were supposed to bring their expertise (inspection/training). This could impede the effectiveness of the internal controls, it said. 

The report said serious non-compliances were systematically found among CBs during unannounced inspections and, in several cases, no action was taken against them. 

In recent years, the frequency of audits for supervising the CBs did not meet NPOP requirements. Furthermore, the scope and focus of the audits were inadequate and inefficient, it said.

The audit said one of the certifying bodies did not have any  documented procedure for risk assessment of operators, which is a violation of the NPOP.

The EU DG Health and Food Safety carried out the audit to verify that the production rules applied in India are those of the National Programme for Organic Production (NPOP), which was transmitted to the European Commission and recognised by the EU as equivalent for certain products.

It was also to verify that the control measures have been permanently and effectively applied and to ensure that APEDA has reinforced its system of controls in the light of the significant occurrence of contamination with ethylene oxide in different organic commodities, in particular sesame seeds.

Action on ETO

The audit team found that in response to findings in the EU of 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). Several shipments from India were rejected due to the presence of ETO in the consignments.   

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

Delhi-based trade analyst S Chandrasekaran said, “NPOP is a fine document that has got endorsement from the EU. The need of the hour is an honest introspection to revamp the organic enforcement system. An unbiased approach will empower the system to arrive at the right decision on the checks and balances.”

He said the immediate need was to carry out a competent audit of CBs and APEDA to protect India’s authentic organic products. 

Related Topics