Organic System Plan

}OSP|

for

Export

Re-Packing and Handling

Storage and Marketing

À

Certification according to …

EU Regulation | NOP | JAS

Name of the Operator (Officially registered headquarters)
Location:
Country:
Year:
Products requested for certification:

Important Information!

All organic standards require a complete description of the export, re-packing, handling and storage site. This so-called Organic System Plan (OSP) constitutes the basis for inspection and certification. Therefore, the OSP should be filled out with outmost care to provide Kiwa BCS with sufficient information for determining compliance with the respective standard. For annual renewal of the certificate, the OSP must be updated if any changes in the production or handling process have occurred. If no changes have occurred the operator is required to submit to Kiwa BCS a written statement, that no changes have occurred and that the previously submitted OSP remains valid.

For EU certification, please check especially the related Chapters II, III, IV and Annex III of the Reg. (EU) 2018/848 and the related delegated and implementing acts, in particular Reg. (EU) 2021/1698.

For NOP certification, please check the relating NOP Organic Agricultural Production Regulations

(§ 205.200 to § 205.206; § 205.270 to § 205.272; § 205.300 to § 205.311).

NOP information resources:

General information: https://www.ams.usda.gov/about-ams/programs-offices/national-organic-program

Legislative text: https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205

NOP Handbook: https://www.ams.usda.gov/rules-regulations/organic/handbook

For JAS certification, please check the relating JAS Notification 1833 on Re-packing of Organic Products,

and – generally - Notification 1971. (Please note: Pure export activities cannot be certified according to

the JAS Law.)

Attached to this OSP you will find for each part of the OSP a brief explanation of the relevant regulations.

Important:	The OSP has to be filled out for one export company only(!). You may include in one OSP	several sites belonging to your company, provided that they are not independent and that	they are working under one management and provided that the measures described in this	OSP apply EQUALLY TO ALL SITES. Please list all sites and their addresses. In case that	your company has various sites which conduct different businesses one OSP per site must	be completed.

Appointment for Inspection

We would like to inform you that according to the legal requirements and our contract, you must be inspected in situ by Kiwa BCS at least once a year (calendar year). In addition, depending on the risk of your operation or other external factors you can be inspected more than once in the same calendar year with or without any further announcement.

Date - and if necessary number of the annual and potentially other risk-oriented inspections – will be determined according to the objective needs. In order to ensure punctual, efficient and economic inspection, we plan a certain schedule. Therefore, an inspection may take place where applicable during the first six month.

We are open for your wishes for the visit, but we have to reserve the right to propose those dates for inspections, and to change them, if necessary.

In case Kiwa BCS has to postpone an inspection visit for unforeseeable reasons, there is no right of the client to claim a certain date and/or reimbursement of eventual costs of preparation. Kiwa BCS will, of course, always propose a new date as near as possible.

In case an inspection date was agreed upon, but due to the clients’ absence could not be realized, and/or if the client did not announce that he would not be able to attend on this day at least 14 days in advance; travel and inspectors’ time costs will be invoiced to the client.

Company information
Address 1 of the Company (contract holder) Address where Kiwa BCS will send the Certificate	Address 1.1 of inspected site (if not address 1) Address where Kiwa BCS will send the Certificate
Company Name:	P.O. Box / Street:
P.O. Box / Street:
Zip Code / Town:	Zip Code / Town:
Province / State:	Province / State:
Country:	Country:
Geographical Reference e.g.: N 49°27’30.86” E 11°5’41.20”	Geographical Reference e.g.: N 49°27’30.86” E 11°5’41.20”
Contact data 1 of owner or legal representative (groups or legal entities)	Contact data 1.1 of responsible person for correspondence + communication with Kiwa BCS
Name:	Name:
Phone:	Phone:
Cell:	Cell:
Fax:	Fax:
E-mail:	E-mail:
Address 1.2 of the production/re-packing and storage site (if it belongs to the company and if it is different)	Address 1.3 of the export unit (if it belongs to the company and if it is different)
P.O. Box / Street:	P.O. Box / Street:
Zip Code / Town:	Zip Code / Town:
Province / State:	Province / State:
Country:	Country:
Geographical Reference e.g.: N 49°27’30.86” E 11°5’41.20”	Geographical Reference e.g.: N 49°27’30.86” E 11°5’41.20”
Contact data 1.2 of responsible person for correspondence + communication with Kiwa BCS	Contact data 1.3 of responsible person for correspondence + communication with Kiwa BCS
Name:	Name:
Phone:	Phone:
Cell:	Cell:
Fax:	Fax:
E-mail:	E-mail:
Comments on relevant business and logistical relationships:
Note: In case the given space does not suffice to list all relations with other companies and own facilities, collection centers and storage locations, please make a complete list of them and attach the list to this OSP..

Attachments to this OSP

Please hand in all necessary attachments with this OSP. The OSP can only be approved if all required documents are available.

Please note the special requirements for NOP retail label approval.

Type of document	To be handed in:	Attachment No.
Signed OSP-Declaration form (D-EN_09-213)	For new operators, or additional standards
Your previous organic certificate and information regarding non-compliances, corrective measures, and sanctions	If this is your initial certification with Kiwa BCS and you were previously certified with a different control body
Drawings / sketch maps of the buildings and units for processing, handling, re-packing, storage, and export, and details about their location (map or geographic coordinates),	For new operators, or if there are changes
Valid organic certificates for all your suppliers	With every OSP update
Other information such as technical data sheets, information about pest control, … if applicable	For new operators, or if there are changes
For EU and JAS: samples of labels used on your products	For new operators, or if there are changes
Fraud prevention plan	Always
Precautionary measure plan	Always
For EU and JAS: samples of labels used on your products	For new operators, or if there are changes
For NOP: Affidavit (s)	If indicated
For NOP: Retail labels (if used)	Always
Only for JAS operators * - if applicable	Detailed descriptions – in written form(!) - of the JAS relevant aspects and procedures - > Standard Operational Procedures= SOPs	For new operators, or if there are changes
“Grading” document (protocol, checklist or other	For new operators, or if there are changes
Documents for all responsible persons (production manager, Grading Manager, etc.) which prove the participation in a JAS training	if available – applicable for new operators, or if there are changes
Other

* If you have not yet received the respective documents or information – please contact your next Kiwa BCS office

Scope of certification:

EU (EU-Market)	NOP (US-Market)	JAS (Japanese-Market)	Other(s)
Other national or private standard
Are there any changes compared to last year?	YES	NO	First inspection
If you apply this year for a new, resp. an additional organic standard - please make sure that an accordingly signed declaration form is available together with this up-dated OSP.
The following activities are covered by this OSP
Distributor	Handling	Storage	Export	Co-Packer (NOP)
Import (NOP)	Trader/Marketer (NOP)	Private Labeler (NOP)	Retail Food Establishment (NOP)	Re-Packing (JAS)
Are there any changes in this part compared to last year’s OSP? YES NO Not relevant - first inspection If yes, please briefly comment: Previous or additional certifications
Is this the first organic certification of your agricultural production site or your company?	YES	NO
Is or was your company or any production site certified organic by another certification body? If YES, please indicate:	YES	NO
Organic Standards?	Month and year of the first inspection?	Recent certificate valid until…:
Previous / former Certification body?
If your agricultural production units (or parts) were certified beforehand, please attach: The last organic certificate Information regarding corrective measures, sanctions, etc..	Attachment No.
If certified by Kiwa BCS before: Since when?	According to which standard(s)?

Precautionary measure plan, measures in case of non-compliance and Fraud prevention plan (only relevant for EU&NOP)

Are there any changes in this part compared to last year’s OSP?	YES	NO
Attach to this OSP the precautionary measure plan designed and put in place in your operation in order to reduce the risk of contamination by non-authorised products or substances and the cleaning measures to be taken throughout the stages of production, preparation and distribution.	Attachment No.
In case of a suspicion of non-compliances due to the presence of non-authorised products or substances, is there a procedure implemented to investigate those cases?	Attachment No.
Attach to this OSP a fraud prevention plan* according to NOP 205.201 (a)(3). *Please always use the document D-EN_14-227_OSP Annex_Organic Fraud Prevention Plan_NOP	Attachment No.

Suppliers of organic products

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection
Is the exporter or re-packer supplied by producers/suppliers belonging to the same company?	YES	NO
Please list all (future) suppliers of your organic products
Supplier	Products	Certified by …	Standard	Certificate valid until …	Attachment No.
EU	NOP	JAS

Reception of products from other units and other operators

On receipt of an organic product from another operator or another unit...
do you check the closing of the packaging or container where it is required?	YES	NO
do you check that the label of the product, or the accompanying (transport) documents linked to the product, contain information on: The name and address of the operator / or owner / or seller of the product The name of the product and a reference to the organic production method The name of the control body certifying the operator / supplier (for NOP certification) and/or code number (for EU certification) and/or JAS seal (for JAS certification) of the control body certifying the operator / supplier A lot number, if applicable?	YES	NO
do you check whether the indication on the label corresponds to the information in the accompanying (transport) documents, and whether the information corresponds to other related documents, such as the supplier’s currently valid organic certificate, or invoices?	YES	NO
Do you systematically document the checks upon reception, as in the above-mentioned points (a), (b) and (c), and are these records available for Kiwa BCS during inspection?	YES	NO
Comment:

Storage and Re-packing

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection

7.1 Storage

Is storage of the organic products done by the operator?	YES	NO
If YES: Are organic products stored separately from those with other status (transition or conventional)?	YES	NO	Not relevant - first inspection
Is the storage of organic products done by another company or a sub-contracted company which is certified independently?	YES	NO
If YES: Which company? Please attach the certificate(s)	Attachment No.
Only NOP: Is the storage facility your operation is using exempt from certification as per NOP §205.101? If yes, attach Kiwa BCS’s document D-EN_14-309_Exempt Handler Affidavit for each uncertified operation.	Attachment No.

Re-Packing

Is any re-packing or handling done by the operator?	YES	NO
Is re-packing or handling done by another company or a sub-contracted company which is certified independently?	YES	NO
If YES: Which company or unit? Please attach the certificate(s)	Attachment No.

Steps of re-packing, resp. handling / separation system

Re-packing / handling step	Separation between different product standards: organic / transition / non-organic *)
1
2
3
4
5
6
7
For a more detailed description, a flow chart is attached to this OSP …	YES	NO	Attachment No.

*) In case there is re-packing or handling also for non-certified products, please describe separation. If necessary, explain also the

separation between products certified organic according to different standards!

Co-packing / labelling on behalf of other companies

Do you pack or label products on behalf of other companies?	YES	NO
If YES, please describe briefly the type of activity you are carrying out on behalf of other companies:
Comment:
Please list below the companies for which you are carrying out activities
Name	Address	Product handled

Sanitation / disinfection / pest-control

Is ionizing/radiation used at any point?	YES	NO
If cleaning/disinfection/pest control agents had contact with the surfaces that enter into contact with organic products, are they all cleaned with pure water?	YES	NO
If YES, please name substance/product and concentration applied:
Comment:
Please describe the measures or methods used:
Measures / methods used for	Measures, methods and products	Attachment No.
Sanitation
Disinfection
Insect control
Rodent control (rats, mice, etc.)
Other (please describe)
For NOP: In case the product is listed with a restriction in the National List of Allowed and Prohibited Substances, please include an explanation on how you verified compliance. For example: 1) Peracetic acid/Peroxyacetic acid (CAS # 79-21-0) - for use in wash and/or rinse water according to FDA limitations. For use as a sanitizer on food contact surfaces. 2) Boric acid - structural pest control, no direct contact with organic food or crops.
Comment:

Transport

Do you transport organic certified products between other companies by yourself?	YES	NO
If not, how do you ensure the integrity of organic certified product during transportation?
Only NOP (§205.101): In case the transportation company does other activities as defined in §205.2 under definition of “handle” than only transport your organic certified product then describe the type of activity carrying out on behalf of your company and please, submit the certificate. Kiwa BCS deserves the right to require Exempt Handler Affidavit to determine compliance.
Attachment No.

Labelling

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection
What kinds of labelling do you carry out? Check/Click all kinds of labelling that apply:
No labelling, only ready labelled products are bought and sold
Retail labels, for point of sale, such as printed boxes or bags, produce stickers, rubber bands or twist ties, bottles, etc. If retail labels are used, please make sure that you complete the related section.
Non-retail labeling for bulk product for storage or shipping containers, such as bin or pallet tags. Nonretail containers used to ship or store raw or processed agricultural product labeled as containing organic ingredients must display at the minimum the production lot number of the product. If lot numbers are used, please complete the related section.
Level	Not relevant	Type of package	Labeled …	Labels include information concerning …	Example in Attachment No.
open	packed	YES	NO	product	quantity	origin	organic status	certifica-tion body
Transport to storage or re-packing / handling unit
Storage of received products
Re-packing / handling
Storage of final products
Sale / Export (final products)
Comment:

EU organic specific labelling requirements

Do your labels include the name and address of the operator and, where different, of the owner or seller of the product?	YES	NO
Do your labels include the code number of the control body which controls and certify the last preparation of the product?	YES	NO
If you display the EU organic Community logo, have you verified that you are using it correctly as defined per Annex V of regulation (EU) 2018/848?	YES	NO
If you display the EU organic Community logo, have you verified that the code number of the certification body and the place of origin (e.g. Non-EU-Agriculture) is correctly placed in the same visual field as the Organic logo of the EU?	YES	NO
If your product is labelled organic, is each relevant ingredient in the ingredient statement identified as organic?	YES	NO

NOP specific labelling requirements

Do your retail labels include the name of producer/handler/distributer of the product?	YES	NO
If you display the USDA organic seal/logo, have you verified that you are using the right colours (NOP 205.311)? Check at: https://www.ams.usda.gov/rules-regulations/organic/organic-seal	YES	NO
If your product is labelled as 100% organic / organic / made with organic, is each ingredient in the ingredient statement identified as organic?	YES	NO
If your product is labelled as 100% organic / organic / made with organic, do the labels contain the statement “certified organic by…” along with the certifiers (Kiwa BCS) name and is placed below the information identifying the handler or distributor of the product?	YES	NO

Retail labelling requirements

Final product label / Retail label – if in use please complete the following questions/tables. Please submit a copy of each label that you use, including labels for co-packing! Below please list each label individually and make sure that you got all, and each label listed! For each label, please attach a copy of it to this OSP!! If needed, please add columns to the table below.
Product name (e.g. Orange juice)	Brand name (if applicable) (e.g. “Organic Juice Heaven”)	Labelling category	Attachment No.
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic

Non-Retail labeling requirements

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection
Do you label non-retail products?	YES	NO

NOP specific non-retail labeling requirements (§205.307)

Non retail for loose products?	YES	NO
Non retail for packaged products?	YES	NO
Do your non-retail labels identify the product as organic?	YES	NO
If your nonretail labels do not identify the product as organic, are you shipping or storing agricultural products packaged for retail sale with organic identification visible on the retail label?	YES	NO
Do your non-retail labels display the production lot number, shipping identification, or other unique information that links the container to audit trail documentation?	YES	NO
Does the audit trail documentation for nonretail containers identify the last certified operation that handled the agricultural product?	YES	NO

Product name	Labelling category	Indicate if loose and/or packaged	Attachment No.
f.ex.: nuts - chopped	100% organic (only NOP)	f.ex. loose
Organic	f.ex. packaged
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic
100% organic (only NOP)
Organic
Made with Organic

Traceability

Are lot numbers or batch numbers used?	YES	NO
If YES: At which levels? What information do they contain? Please describe:
Comments:
Is there a traceability system implemented which allows the tracing back of each delivered lot to its supplier?	YES	NO
If YES: Please describe how your traceability system functions and give an example (for example: XXXX-YY-ZZZZ, day of production XXXX, product code YY, status ZZZZ)
Comments:

Record-keeping / documentation

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection
How do you register/document the activities done in the operation?
Digital merchandise management system	YES	NO
Digital record keeping with excel sheets or similar	YES	NO
Manual paper lists	YES	NO
Notes on calendar or maps	YES	NO
Comments or others:
Records about …	exist	partly	do not exist	not relevant
Do you keep separate records for organic and non-organic production?
Does your recordkeeping system permit accurate tracking of organic products from receiving through sales?
Do you keep records about the precautionary measures implemented in all production stages?
Do you keep records on product purchase?
Purchasing orders
Purchasing invoices
Total amount of organic product purchased
Do you keep storage records?
Records on crop quantities
Repacking /Handling (e.g. Packaging)
Pest control
Invoices of disinfectants and pesticides
Do you keep separate records for organic and non-organic production?
Cleaning of processing/ handling facilities and storerooms
Separated storage
Do you keep records on sales / delivery of products?
ÆSales invoices
Shipping/delivery records
Waybills, bills of lading etc.
Annual total sales

Please note that for certified products all sales of product must be documented, including those sales of certified product made without reference to organic agriculture (sales as non-organic)!

Pollution risk / treatment of disposals

Do organic products have contact with prohibited or other polluting substances (e.g. wood preservants, fuel, detergents, etc.) during transport, reception, processing or storage?	YES	NO
Are all recipients used during transport, processing, and storage, appropriate for foodstuff?	YES	NO
Are these recipients thoroughly cleaned before being used?	YES	NO
If water is used in the processing – where is the wastewater treated?	Municipal	Own plant	No treatment	Not relevant
In case of NOP certification: If chlorine is added to the water used during processing – is it diluted before disposal (allowed quantity: 4 ppm)?	YES	Partly	NO	Not relevant

Quality Management

Are there any changes in this part compared to last year’s OSP?	YES	NO	Not relevant - first inspection
Does the company have a documented Quality Management System (QMS)?	YES	NO
If YES: Does your Quality Management Handbook (QMH) include specific chapters for handling/re-packing of organic products?	YES	NO	Not relevant
Do you have a quality monitoring program for organic products that allows you to detect problems in your product (systematic quality control of products, such as sampling and analysis)?	YES	NO
If YES: Please describe the type of quality checks that your carry out, such as water tests, sampling and analysis of product etcetera, and how often you carry out these checks. Please include an attachment with further details, if necessary.
Comments
If YES: Do you document the internal quality checks?	YES	NO
Who is the Quality Manager?
Does the Quality Manager perform internal audits?	YES	NO
If YES: Are the results documented?	YES	NO
Is the handling of complaints regulated in your QMH?	YES	NO

OSP - Monitoring

Explain how you verify your operation’s OSP is implemented and how you update your OSP in case of changes. (NOP§205.201 (a)(3))
Attachment No.

Input Verification

For NOP: Please be aware that if your operation is using any kind of inputs (ingredients, processing aids, post-harvest handling substances, sanitizers, and facility pest control materials) an approval procedure must always be submitted. If you use an input with an annotation in the National List, you must provide proof and an explanation on how you verified compliance with this annotation. If you already attached evidence under a different point in the OSP, please reference it below.
​Please attach your procedure describing approval of inputs and how you assure compliance with the regulation and restrictions, including a description on how you verify compliance of inputs with an annotation in the “National List of Allowed and Prohibited Substances”. If the inputs that you use have restrictions or annotations*, explain how you assure compliance with the regulation and the restrictions that these inputs have. Attach corresponding evidence. References: (§205.201 (a)(2), §205.201(a)(6), §205.270 (b), (c), + §205.601 – 606)	Resources which can be used to verify compliance with the regulation, but are not limited to, are listed below. Please check the corresponding boxes or indicate if you used other resources. Attach evidence of your verification (f.ex. input certificates, data sheets, etc.). ☐ OMRI ☐ Input and material review program Please indicate which one (f.ex. EPA, WSDA, ECOCERT, CAAE, Kiwa BCS, CDFA) ☐ Review of NOP regulation “National List of Allowed and Prohibited Substances” ☐ Other	Attachment No.
☐ Input approval procedure ☐ Verification evidence:

Note: In the case of an initial certification process, Kiwa BCS reserves the right to not proceed with approval of the organic system plan as well as with the certification process and take relevant actions.

Confirmation by the operator
I confirm that all above mentioned information represents fully and accurately the operation and that I have read and signed the obligatory declarations (please see section Attachments to this OSP) relevant for the standard according to which certification is applied for. Place: Date: Signature of the farm’s/company’s representative: Name (in block letters) of the farm’s/ company’s representative:

This part is for Kiwa BCS internal use only (!)

Kiwa BCS result of OSP verification:

Type of client/inspection …

new client/project first application
follow-up inspection/certification

The operation/project is …

recommended for	EU	NOP	JAS	certification.
recommended for	EU	NOP	JAS	certification, ...
… on condition that:
not recommended for	EU	NOP	JAS	certification.

Date:

Signature of Kiwa BCS responsible person:

Name (in block letters) of Kiwa BCS responsible person: