Ingredient status, formulation calculations and the permitted finished-product claim should be traceable. Source documents must connect to the actual product rather than merely exist in a file.
Compare product name or code, producer, scope and relevant period with batch records. Explain differences in trade names. A general company certificate does not mean every ingredient is organic. Examine processing and repacking in the supply chain where necessary.
Check the programme's separate ingredient and label conditions for each category. Shared rules do not make them equivalent. Eligibility for one category does not automatically permit another category's logo. State the intended output in the application and assess calculations and product lists accordingly.
Assess ingredient and product identity, storage, equipment use and cleaning. Apply the programme's separation and contamination controls. A shared facility neither gives every product the same status nor automatically prevents coverage in every case. Demonstrate control of the actual production flow.
Do not retain the previous organic claim without assessing the substitute's status and formulation effects. Determine required approval, calculations and label changes. Trace affected batches clearly. Urgent purchasing does not automatically alter the approved recipe or programme conditions for the finished product.
Identify the content and calculation behind the percentage and match logo use to current product scope. Avoid presenting an ingredient proportion in a way that confuses it with the whole product's status. Review programme labelling guidance alongside applicable cosmetic claim rules.
Identify differences in ingredient acceptance, permitted processes, proportions and labels. Confirm whether existing evidence can be used with the new body. Replacing the logo on an old document is not an adequate transition. Allow for assessment, possible reformulation and packaging stocks in the timetable.
Content reviewed:
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