As reported in the February issue of TOS (issue no. 106), concerns about GMO contamination of organic cotton, whether unintended or due to either negligence or fraud, have become a major issue in the organic fibre sector.

At the BioFach Congress in February, there were several publicpresentations on this issue, including ‘GM Cotton at H&M and C&A –scandal or not?’ and a presentation given by the Indian organic authorityAPEDA on its new web-based traceability programme, Tracenet, which addressedthe full spectrum of organic product value chains. In addition, the subjectof how best to prevent unintended contamination and detect fraud in theorganic supply chain was a prime topic of discussion at meetings held by theGlobal Organic Textile Standard (GOTS). The group calling itself theConsortium on Integrity of Organic Cotton also addressed this topic alongwith various other topics concerned with organic cotton integrity.

This report focuses on discussions at meetings held by GOTS and by theConsortium on Integrity of Organic Cotton, a group formed by Solidaridad,Organic Exchange (OE) and ICCO, a Dutch development organisation.

GOTS discussions focused on means of identifying and reducing the risk ofGMO contamination in organic cotton. Detection of GMO material in cottonbeyond the ginning stage, when all seed and other plant material thatcontains DNA is removed from the fibre, is not reliable and is virtuallyimpossible to accurately quantify. A simple inexpensive test for GMO presencecould be used at the ginning stage to indicate whether there is contaminationpresent in an organic batch, and if so it could trigger an investigation intothe level and source of the contamination. No definite tolerance level forcontamination in cotton has been identified; although the EU requires anyfood product tested as containing more than 0.9% GMO material to be labelledas a GMO, this does not apply to fibre.

Managing cotton ginning

In order to tighten the GOTS quality assurance system, the TechnicalCommittee is proposing to require GOTS certification of cotton ginning. Thiswill allow inclusion of a risk-based test for GMO contamination at the stagewhere a reliable result can be obtained. Once cotton is ginned, that is, whenthe seeds and leaf matter are removed, little or no genetic material remainsin the fibre. Therefore, testing for GMOs beyond the ginning stage is notreliable. Up until now, GOTS certification requirements have not extended tothe ginning stage, which may sometimes be conducted on farm and may beconsidered to be a form of post-harvest handling. GOTS deals only withtextile processing and manufacturing stages, and requires that raw fibre becertified according to the standards of the country where the final productwill be marketed. In most cases this means either EU or USDA-NOPcertification. The National Organic Program (NOP) permits certification ofcotton ginning, even though it does not consider textile processing to bewithin its scope, since cottonseed meal and oil is used for both livestockfeed and human consumption. However, the EU does not consider ginning withinits scope.

Problems can arise for a ginnery that is already NOP or EU certified if italso has to obtain certification from a GOTS certification body. A possiblesolution is to allow the NOP or EU accredited certification body to serve asa subcontractor to a GOTS certification body, with additional inspectionrequirements (e.g., seed sample collection) specified. In some cases thiswill also require the certifier to conduct a social audit of the ginnery,which is not required under NOP or EU standards.

Additional proposals for strengthening GOTS quality assurance includerequiring a Transaction Certificate (TC) for each step in the supply chain.Information needed on such TCs would include whether the raw fibre wascertified according to the NOP, since this information is difficult to verifyin a complex textile supply chain. Another proposed requirement was that aminimum of 2% of GOTS certified operations should receive announcedinspections.

The GOTS International Working Group (IWG) also participated in part of themeeting on Integrity in the Indian Organic Cotton Value Chain, held atBioFach on 19 February. In addition to the IWG representatives, about twentyinvited participants, including representatives of internationalcertification bodies working in India, packed the small meeting room. The aimof the meeting was to initiate a meaningful dialogue with all stakeholdersinvolved that addressed potential challenges and to find directions forimprovements. Prior to the meeting, ICCO, Solidaridad and OE formed a Consortiumon Organic Cotton Integrity and commissioned a survey to identify potentialweak links in the system. A draft report discussing the results of thissurvey was circulated in advance, and this was also discussed at themeeting.

According to the introduction to this report, India was chosen as the casestudy for this survey, due to its prominent role in organic cottonproduction. However, the report notes that the issues it highlights are notunique to this one country, but are relevant to the sector globally.

An important conclusion of the survey is that each stakeholder group in theorganic cotton system is facing challenges, and that there is scope forimprovement and further strengthening of the system on all levels. Criticalissues are described with regard to the farm level certification andaccreditation, as well as challenges resulting from the realities of theorganic cotton fashion industry. Some examples of critical issues described include:

• The limited availability of non-GM cotton seeds approved for organiccotton production.
• Weak Internal Control Systems (ICS) for small farmer groups.
• Dual certification.
• Errors in yield estimates.
• Lack of mutual cooperation between certification bodies to address commonchallenges.

Examples of realities in the textile sector, which contribute to thechallenges described above, include the drive to reduce the price differencebetween conventional and organic cotton prices, lack of long termcommitments, and the inability to support farmers with pre-financing.

Key areas

At the meeting the group of certification bodies emphasised the fact thatresponsibility is shared throughout the value chain, and that most of theproblems identified also occur in countries other than India. The groupdiscussed how to tackle some of the issues and challenges identified in thedraft report, and also noted the need to collaborate with other organisations.One step that everyone agreed would help was creation of a certificationbodies regional Round Table to address common challenges. Potential topicsthat such a Round Table could address are to create more alignment, develop aCode of Conduct, develop guidance documents, and perhaps form a grievancecommittee to collaboratively resolve issues that arise.

The meeting was introduced by Katherine DiMatteo, IFOAM World BoardPresident, who noted that this first meeting was intended to solicitstakeholder input and feedback for the Consortium. Conclusions from the meeting will be taken into account in further meetings with other stakeholders. LaRhea Pepper, Senior Director of Organic Exchange, thensummarised some of the key areas of concern highlighted in the report. Therewas a particular emphasis on the certification system as this is the primaryfocus of the group of stakeholders attending. While discussing the complexityand feasibility, in the short and long term, of these topics the meeting alsodevised potential solutions and improvement options.

Follow up

A summary of this meeting, entitled ‘Highlights of the 1st stakeholdermeeting with the Certification Bodies’ was later circulated by theConsortium, which stated that the group of certification bodies was satisfiedwith the report and its depiction of issues and challenges.

Interested stakeholders can request a copy of the report and ask toparticipate in future stakeholder discussions by contacting ICCO, Solidaridador OE. The next stakeholder meeting took place in India on 3 May.

Grace Gershuny This e-mail address is being protected from spambots. You need JavaScript enabled to view it

The author serves as a representative to the GOTS Technical Committee onbehalf of the Organic Trade Association (OTA).

Contact for Consortium on the Integrity of Organic Cotton: ICCO - Marian van Weert This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Solidaridad - Marieke Weerdesteijn This e-mail address is being protected from spambots. You need JavaScript enabled to view it OE – This e-mail address is being protected from spambots. You need JavaScript enabled to view it