The much-anticipated Regenerative Organic Certification (ROC) food labeling scheme will not start taking applications from food industry brands and farms this month as previously anticipated.
The Regenerative Organic Alliance (ROA), the nonprofit managing the “holistic” labeling scheme, said Monday that the audits of nearly two dozen leading organic and natural brands and farms participating in the ROC’s pilot program would push into “early autumn.”
The ROA’s goal, as stated on its website, was “to conclude our pilot audits by summer 2019 and be ready to open to general ROC applications by September.”
Earlier this year, the group had declared that the ROC would “officially launch in the first quarter of 2019.”
The ROC is an add-on to the USDA’s National Organic Program (NOP) standards with enhanced certification criteria focused on three pillars: animal welfare, soil health and social fairness label.
The ROC covers requirements for farming and ranching operations, transportation, slaughter and certain processing facilities that produce food and fiber. The ROC prohibits certain growing methods such as hydroponics, aquaponics, soilless practices and container growing where crops are never integrated into a field.
Once the audits are completed, lessons learned will be incorporated into a final ROC standard.
“The next two months will reveal the strength of the ROC Standard and new improvements to the framework overall,” the ROA said in its newsletter on Monday.
NSF International is coordinating the pilot program with the 22 organic and natural brands and farms – including Danone’s Horizon Organic and Vega brands, Nature’s Path’s Legends Organic Farm, Guayaki yerba Mate, and Maple Hill Creamery – that are testing the ROC audit process and certification criteria.
The farms involved are based in nine countries, including Ghana, India, and Sri Lanka. The pilot will help NSF determine the ROC cost structure, including cost of inspection and cost of labeling.
NSF also serves as the oversight body of the ROC program and will oversee the collection of data, management of audit information and reports, and be responsible for approving and onboarding certification bodies.
So far, ROA said on Monday, four certification bodies have been approved, including NSF’s Quality Assurance International (QAI), based in San Diego. The other three are Gainesville, Fla.-based Quality Certification Services (QCS), France-based EcoCert, and Guatemala-based MayaCert S.A. ROA said more will be onboarding in January.
“The ultimate goal of the ROC is to build off of existing certifications and partner with certification bodies that can audit to the ROC requirements in addition to the baseline certifications,” said the ROC’s new Equivalency Gap Analysis, another new resource recently released, which details add-on requirements. “In the early stages, additional audits may be required as we work towards onboarding more certification bodies with expertise in each of the pillar areas.”
There are three levels of ROC certification:
- Bronze: Can be claimed publicly; however, no product labeling is permitted. Annual recertification is required. After three years of Bronze certification, an operation must advance to Silver or Gold if it wishes to make continued public claims. To claim ROC at the Bronze level, at least 50 percent of fiber-or-food-producing land must be certified.
- Silver: Product labeling is permitted. Annual recertification is required. To claim ROC at the Silver level, at least 50 percent of fiber-or-food-producing land must be certified at initial certification and must reach at least 80 percent by year five.
- Gold: Product labeling is permitted. Annual recertification is required. To claim ROC at the Gold level, 100 percent of fiber-or-food-producing land must be certified.
There are also various categories of labeling based on the use of ROC ingredients in a product:
- “100% Regenerative Organic Certified” means that the product was produced and processed using only regenerative organic methods and regenerative organic ingredients (excluding water and salt but including processing aids). These products cannot contain any banned ingredients from the National List of Allowed and Prohibited Substances. The Regenerative Organic Certified logo is permitted on the product. Most products in this category are single ingredient products.
- “Regenerative Organic Certified” means that the product was produced using organic methods and contains a minimum of 95% regenerative organic ingredients. The Regenerative Organic Certified logo is permitted on the product. The non-organic ingredients in these products must be non-GMO, must not be irradiated, and must not have been fertilized with sewage sludge, as defined by the National Organic Standards Board.
- “Made with regenerative organic ingredients” products contain between 70% and 95% regenerative organic ingredients. They can use the wording “made with regenerative organic – “ and list up to three ingredients or food groups on the front panel. These products cannot include the Regenerative Organic Certified logo anywhere on the package. The non-organic ingredients in these products must be non-GMO, must not be irradiated, and must not have been fertilized with sewage sludge, as defined by the National Organic Standards Board.
- Products with fewer than 70% regenerative organic ingredients or less can use the words “regenerative organic” to specify regenerative organic ingredients in the ingredient panel. These products are not permitted to have the Regenerative Organic Certified logo or make any front panel claims about regenerative organic certification.
Chain of Custody requirements
The Chain of Custody Guidelines outline the requirements for organizations that buy, sell, store, process, or transport product intended to carry ROC claims.
Certain processors or manufacturers that handle certified product are subject to chain of custody and audit requirements. For products to be sold with the ROC Gold claim, certain processors may also be required to achieve ROC certification. However, for ROC Bronze and Silver levels only the farm or ranch is required to be certified to the ROC standard.
The Chain of Custody requirements apply to companies that:
- prepare, mix, or package raw material (primary processors)
- further process or package ROC-certified goods
- store or transport certified product that is not enclosed or pre-packaged for the entire duration of ownership
Companies that are exempt and not required to submit to ROC chain of custody audits align with the USDA’s NOP requirements and include:
- retail food establishments that handle, but do not process, certified product for sale to consumers
- retail food establishments that sell packaged, labeled product to consumers
- a processing or handling operation that only handles ROC Silver or Gold product that amounts to less than 70 percent of the finished product by weight, or that only handles ROC Bronze product
- an operation that handles only packaged or enclosed ROC product that remains in the same package or container for the entire duration of ownership
- an entity that does not take legal ownership of the ROC product, such as for transportation or distribution of finished goods
Another new resource is the Labeling Guidelines, which describes the type of ROC label allowed on-product dependent on the claimable material content of the product.
For instance the content claim must specify the certification level claimed (i.e. Silver or Gold) through the use of the Silver/Gold colored ROC logo (where allowed) or a text distinction.
For all claims, the complete phrase “Regenerative Organic Certified” must be used. Abbreviations such as “ROC” or “regenerative organic” are not permitted.
Product that contains at least 95 percent ROC material by weight may use the “Regenerative Organic Certified” claim and/or the applicable ROC logo. The remaining non-claimed material (up to 5 percent of the product, by weight) may be organic or non-organic (conventional). Any non-organic ingredients must meet the criteria of NOP labeling standards for allowable production methods and excluded substances (e.g. non-irradiated, non-GMO, etc.).
The ingredients panel must identify regenerative organic certified ingredients via text (e.g. regenerative organic certified wheat) or a symbol or other demarcation (e.g. asterisks). If a product contains both Silver and Gold content, any claims must defer to the lower certification level.
Products that contain at least 70 percent and less than 95 percent ROC material by weight may use the “Made with Regenerative Organic Certified [X]” claim on the principal display panel, where certified ingredients or ingredient categories are specified. The finished product must not use the ROC logo, be represented as a Regenerative Organic Certified product, or state “Made with Regenerative Organic Certified Ingredients”. That is the “Made with” claim must be specific to the ROC ingredients contained in the product.
The “Made with” claim may list up to three ingredients or ingredient categories that are fully claimable as ROC. For example, allowable claims include “Made with Regenerative Organic Certified carrots, tomatoes, and onions”; “Made with Regenerative Organic Certified vegetables”; or “Made with Regenerative Organic Certified nuts and wheat.”
Content Claims Summary
There is also a FAQ for ROC participants here.