MOSA has Updated our Imported Grain Policy

Notice Regarding Requirements for Approval of Grain Shipments Imported from Eastern Europe and non-EU member states

In response to the discovery of fraudulent imports of soybeans and corn from Turkey (produced and handled in Kazakhstan, Moldova, Romania, Russia and Ukraine) that violated federal organic regulations, MOSA, with other accredited certifiers, is implementing additional requirements for approval of shipments of at-risk commodities from Eastern Europe. Certain corn and soy handlers involved in the supply chain falsified documents to misrepresent non-organic products as organic. Anytime there is fraud anywhere in the organic system, it devalues our Organic Seal, and hurts organic farmers. The success of the organic industry has resulted from the integrity of the organic certification process and organic operators’ commitment to compliance and enforcement. Oversight of foreign organic suppliers must be robust. Fraud cannot be tolerated.

In order to deter any additional fraudulent shipments and protect the integrity of the organic system, MOSA is proactively implementing additional control measures, to help prevent future incidents of fraudulent imports. In 2016, the USDA National Organic Program (NOP) directed certifiers operating in Eastern Europe and Turkey to increase oversight of grain exporters in certain countries. This included additional unannounced inspections and mass
balance audits, as well as sampling and testing of each corn shipment destined for the U.S. MOSA and the NOP are now expanding the additional oversight to include soy, edible dry beans, wheat, flax and sunflower meal. These requirements are being implemented for shipments received directly from handlers operating in Kazakhstan, Moldova, Romania, Russia, Turkey, and Ukraine.

Any MOSA-certified operator that receives imported grain directly from a ship must enable unannounced inspection(s), demonstrate full traceability along with volumes, and must enable pesticide residue and GMO sampling for each at-risk shipment. Any shipments that MOSA does not specifically approve are considered to be noncompliant with requirements to provide information necessary to verify compliance. Applicable National Organic Program regulations include sections 205.2 "Audit Trail"; 205.103; and 205.201 (a)(6).

MOSA will review applicable records and disclosures, and will work with other regulatory agencies as necessary to ensure that volumes are legitimate, that products are not treated with prohibited materials in the supply chain, and that products meets organic standards.

Operations that receive imported grain shipments are strongly advised to consider their suppliers very closely and review, test and/or visit the production locations to verify the legitimacy of products. Operations with commodities found to not meet organic standards will be notified that that product is not compliant. If an operation knowingly sells noncompliant product as organic it may lead to suspension of organic certification and potential civil penalties.

We recognize that verification of organic status for imported grain may be challenging and complicated to achieve. We also recognize that there may be challenges for US operations as international traders and certifiers adjust to additional documentation requirements. We appreciate the patience and dedication of MOSA-certified operations in responding to these additional requirements and helping us to maintain organic integrity. Working with us like this helps to defend organic standards and ensure continued consumer confidence in organic. Thanks for your help with the additional diligence needed at this time.

In addition to this policy specific to Eastern European imports, please note that MOSA will be increasing scrutiny in our organic system plan review and during annual inspections to ensure organic integrity in the supply chain in general, especially when parts of the supply chain are uncertified, or when organic commodities come from foreign sources. MOSA is also conducting extra unannounced surveillance inspections of some brokers, traders, and larger feed handlers who may source imported grains.

MOSA’s formal policy is attached