Abstract
The Certification and Accreditation Administration of the People's Republic of China (CNCA) has recently officially issued the new version of the Implementation Rules for Organic Product Certification (CNCA-N-009:2025) (hereinafter referred to as the "New Rules"), which will formally take effect on 1 January 2026.
This revision features substantial amendments, detailed requirements and stringent supervision, aiming to further strengthen the primary responsibility of enterprises, ensure the quality of organic products and enhance the credibility of the industry. To assist relevant enterprises in making early preparations and achieving a smooth transition, the key changes of the new rules are summarized as follows:
1.Basic Qualifications and Responsibilities (corresponding to Clause 5.2.1 of the New Rules)
1)The certification applicant and its entrusted producers, processors or operators shall obtain the administrative permits required by relevant laws and regulations, where applicable.
2)The certification applicant shall own the title to the products and bear full responsibility for product quality.
2.Management System Operation Requirements (corresponding to Clause 5.2.2 of the New Rules)3.Verification of Certificate Revocation History (corresponding to Clauses 5.2.4 and 5.2.5 of the New Rules)
1)The certification applicant and its related parties have not had their organic product certification certificates or organic conversion certification certificates revoked for specified serious violations within the past five years.
2)The products applying for certification and their production and processing sites have not had their organic product certification certificates or organic conversion certification certificates revoked by a certification body for other reasons within the past year.
4.Credit Record Verification (corresponding to Clause 5.2.6 of the New Rules)II. Detailed Requirements for Application Materials
Additional Conditions for Application Acceptance(Items (1), (2) and (3) correspond to Clauses 5.2.7(1), (2) and (8) of the New Rules respectively)1)Copies or scanned originals of legitimate business qualification documents of the certification applicant and its entrusted producers, processors or operators.
2)Basic information of the certification applicant and its organic production, processing and operation activities: Name, variety and production scale (area, yield, quantity, processing volume, trading volume) of the products applying for certification; basic information of non-certified products and products produced by non-organic methods within the same production unit.3)Valid conformity certification materials such as origin environmental quality monitoring (inspection) reports or monitoring (inspection) conclusions.
III. On-site Inspection and Post-certification Supervision
1.Clarified Validity Period of Origin Environmental Quality Certificates(corresponding to Clause 5.5.3 of the New Rules)
1)The validity period of processing water test reports shall not be earlier than 12 months before the inspection date.
2)The validity period of other environmental monitoring reports shall not be earlier than 24 months before the inspection date.
3)For origin ambient air quality, public information issued by ecological and environmental departments at or above the county level may be accepted.
2.Detailed Post-certification Supervision and Sampling Testing in the Circulation Sector(corresponding to Clauses 6.1 and 6.2 of the New Rules)
1)Certification bodies shall conduct unannounced on-site inspections of at least 5% of certified organizations each year. A new sampling inspection requirement is added for organizations that have not yet used the organic logo, with a ratio of no less than 10%.
2)A new requirement is added to conduct sampling testing of products bearing the organic logo in the circulation sector each year, with a sampling ratio of no less than 10%, and at least one product per certified organization shall be sampled.
3.Improved Information Change and Traceability Management Systems(corresponding to Clauses 6.3.2 and 6.4.7 of the New Rules)
1)Changes in the legal representative or actual controller, registered address and contact address of certified organizations.
2)Certified organizations shall establish a traceability system related to sales certificates and organic codes to achieve full-process traceability from raw materials to finished products. Certified organizations are encouraged to digitalize the traceability of sales certificates and organic codes.
IV. Supplementary Requirements for Organic Goji Berry Certification(Special Notice for Organic Goji Berry Producers)
1.Production Unit Requirements(corresponding to Annex 6, Section I (1) of the New Rules)
The establishment of buffer zones between organic goji berry production units and surrounding conventional agricultural areas shall fully consider environmental factors (e.g., the location of the organic production unit on slopes, pesticide application in surrounding conventional agriculture) and climatic conditions (e.g., wind speed and direction during high-risk seasons) to ensure the integrity of organic production.For flat terrain with surrounding conventional fruit trees or goji berry orchards, the buffer zone shall be more than 50 meters.For surrounding conventional crops of other types, the buffer zone shall be more than 30 meters.
2.Documentation and Record-Keeping Requirements(Item (1) corresponds to Annex 6, Section II (1); Item (2) corresponds to Annex 6, Section II (2) of the New Rules)
1)The certification applicant shall formulate effective control measures for major diseases, insect pests and weeds in the organic goji berry production technical specifications, and develop effective soil fertility improvement plans, including but not limited to:
① Control measures for insect pests such as goji berry psylla, goji berry gall mite, goji berry aphid, goji berry leafminer fly, goji berry gall midge, goji berry fruit fly and goji berry thrips;
② Control measures for diseases such as goji berry black fruit disease (anthracnose) and goji berry powdery mildew;
③ Weed control measures;
④ Soil management and fertilization plans.
2)The certification applicant shall establish and retain the following production records and relevant conformity documents, which shall meet the requirements below in addition to GB/T 19630:
① Purchase records of externally purchased plant protection products (including at least manufacturer name and contact information, pesticide registration number, production date/batch number, etc.), conformity documents for products permitted in organic production, photos of packaging, etc.;
② Electronic materials such as relevant photos shall be kept in original form for a retention period of at least 5 years.
V. Four Urgent Recommendations for Certification Applicants
- Organize training immediately: Arrange key internal personnel to study the new rules as soon as possible and fully understand the updated requirements.
- Conduct comprehensive self-inspection and rectification: Conduct a thorough internal review of qualification documents, management systems, production records and traceability systems in accordance with the new rules.
- Update system documents: Begin revising quality management manuals and operating procedures to ensure consistency with the new provisions.
- Verify validity of certificates: Focus on checking whether environmental monitoring reports and other documents are within their validity period, and arrange for renewal testing in advance.