Certification is not a one-time event. The scope certificate is annual, inspections are annual, and a single serious finding can suspend everything you have built. This episode covers what keeps certification alive, what ends it, and what you can do when you disagree with a decision.
The deadlines that matter
- 45 daysBefore your scope certificate expires โ the latest to apply to change certification body
- 3 weeksFor your current body to issue the NOC, once dues and non-compliances are cleared
- 30 daysTo file a first appeal against a certification decision
- 2 + 3 monthsFor the first appeal to be decided, then a second appeal at the NAB level
The Annual Cycle
Each year brings an announced inspection of every operator, with the risk-based additional and unannounced visits described in episode 5, and a new scope certificate issued on TraceNet. Non-conformities raised at inspection have to be closed; open ones follow you, even to a new certification body.
Changing Certification Body
- Apply for a No Objection Certificate on TraceNet to your current body, at least 45 days before your scope certificate expires.
- Before applying, clear all dues with the current body and submit corrective action for any pending non-compliances.
- The current body issues the NOC within three weeks of your application, subject to those conditions โ and your file and reports transfer online to the new body.
- You must hold a valid certificate while the NOC is issued and you register with the new body.
- The new body must see the earlier body's non-conformities closed before it issues your scope certificate.
Miss the window and the door shuts: once your scope certificate has expired, you cannot register with another certification body even if you have obtained the NOC. Switching is something to decide at mid-season, not in the final month.
Individual farmers in a grower group can also move: with an NOC from the certification body at the start of a new season, a farmer may transfer to another grower group in the same geographical area, or form a new group with other farmers there.
Enter your scope certificate's expiry date to get your deadlines:
This interactive tool needs JavaScript. The rules it applies are set out in the text of this episode.
Sanctions
Every certification body must have a clear sanctions policy and a documented sanctions catalogue covering minor and major infringements โ and the catalogue must provide for repeated minor non-conformities to be upgraded to major. For a grower group, a sanction applies to the entire group where inspection of the representative sample shows that the Internal Control System has failed to comply with the norms.
Withdrawal and Termination
| Finding | Consequence |
|---|---|
| An infringement affecting organic integrity | The non-compliant lot is removed from the entire lot of the affected production cycle |
| Serious non-compliances affecting organic integrity | Certification withdrawn for a specified period |
| Severe infringement or repeated violations | Certification terminated |
Withdrawal and termination decisions are reported to APEDA and published on the certification body's website โ a public record that buyers can find.
Your Right of Appeal
decision"] -->|"Within 30 days"| B["First appeal: the body's
own appeal committee"] B -->|"Decided within
2 months"| C{"Satisfied?"} C -->|"No"| D["Second appeal:
NAB Sub Committee"] D -->|"Ordinarily within
3 months"| E["Final decision"]
- The first appeal goes to the certification body's appeal committee within 30 days of the decision being communicated, and must be disposed of within two months. The committee must be independent of certification activities and free from conflict.
- If you are not satisfied, a second appeal lies with a NAB Sub Committee set up to hear such appeals. It ordinarily decides within three months, and if it needs longer it must tell you why in writing.
- Your certification body must tell you the appeal procedure at the time of certification โ ask for it then.
An appeal is decided on records. Inspection reports you were given, corrective actions you submitted, test reports and TCs are what carry it. The operators who win appeals are usually the ones whose files were already in order.
Last in the series: importing organic ingredients, re-exporting, and the full checklist from zero to shipment. KrushiFlow validates these fields and submits farmer records to the portal in bulk.