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IOAS comment on the New York Times article ‘That Organic Cotton T-Shirt May Not Be as Organic as You Think’ published February 13, 2022

IOAS is a US-based, non-profit, accreditation body operating worldwide. We specialise in the assessment and oversight of certification bodies working in the field of organic and sustainability standards. Now in our 25th year of operation we are a non-governmental, independent organisation with a mission of ‘Cultivating integrity and trust across the organic community’. We are a member and signatory of the International Accreditation Forum Multilateral Agreement which operates a peer review system amongst many national and international accreditation bodies.

Regarding the NYT article of February 13, 2022, we would like to comment the following:

  1. Given our mission, any claim or identification of fraud in the organic sector is of concern to IOAS. We have performed our own review of events in India over the last year as well as consulting previously with the US National Organic Program to analyse risk in organic supply chains. Unfortunately, in any supply chain, fraud is more likely to happen where there is high demand, a price premium, a supply shortage, and the supply chains are long and complex. Key to countering this are investment and support to farmers by buyers and brands, as well as a coherent and rigorous risk-based certification system. IOAS works with others on continuous improvement of the systems under our control and to address and uncover fraud.
  2. IOAS is one of several accreditation bodies that is engaged with schemes like GOTS and Textile Exchange and others operated by governments to verify the competence of certification bodies in implementing their standards. IOAS currently assesses 81 certification bodies around the world, 19 of which are accredited in the organic textile sector. Other accreditation bodies and government agencies oversee other certification bodies in India and around the world.
  3. IOAS has the independent power to sanction and ultimately withdraw accreditation when it determines certification bodies are not meeting the applicable standards. The NYT article accurately states that IOAS recently withdrew the accreditation of one of the certification bodies active in India in the certification of cotton products under GOTS and Textile Exchange. We have also withdrawn the accreditation of another certification body working in the textile sector in India during the last two years and have issued lesser sanctions to others.
  4. The certification systems that IOAS oversees are all based on standards set by the International Organization for Standardization (ISO). These norms have clear requirements on impartiality including separation of the inspection process from the certification decision to avoid conflicts of interest.
  5. Scheme owners normally adapt the ISO standards to their specific sector. Typically, as well as an annual inspection, they require additional and unannounced inspections based on risk assessment, as well as testing for both GMOs and pesticides. Besides annual certificates for the production units, each consignment also requires a transaction certificate, issued on verification of raw materials. Records of all these must be kept so that traceability can be checked.
  6. Certification bodies in nearly all schemes operating around the world, including the USA, are paid by the clients seeking certification, i.e., a fee-for-service business model. The only real alternative is certification by government agencies paid for by taxpayers. This is rare and has its own shortcomings. The critical drivers for maintaining integrity are strong accreditation and scheme requirements within an effective legal framework, the commitment and diligence of the certification body staff and clear traceability within the supply chain.
  7. GOTS and Textile Exchange are both processing standards; therefore, certification of raw cotton production is outside of their scope. This is often controlled by national legislation so collaboration between such systems is also critical.
  8. The fact that IOAS has sanctioned certification bodies, and the US and European Union authorities have taken their own action (unrelated to textiles) makes clear that certification is not always implemented as it should be. It does however demonstrate that the oversight system responds and has teeth and reflects the dedication of many actors working worldwide to maintain the integrity of organic products.

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GOTS, Textile Exchange

Organic & Natural Cosmetics


ISO/IEC 17065 Accreditation


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