Interpretation of the Revision of the "Implementation Rules for Organic Product Certification"
In September 2025, the Certification and Accreditation Administration of the People's Republic of China (CNCA) issued the 2025 version of the "Implementation Rules for Organic Product Certification" (CNCA-N-009:2025), along with the official interpretation. The new rules will come into effect on January 1, 2026, and the 2019 version will be simultaneously abolished. The 2025 version of the rules optimizes the management of organic product certification through strict entry requirements, detailed standards, strengthened supervision, and full traceability. It sets higher requirements for certification bodies, production, processing, and business enterprises. All certification enterprises should pay attention.
I. Detailed Requirements for Certification Application
When applying for organic product certification, the certification applicant must meet the following requirements:
1) Obtain legal business qualifications. The certifying client and the entrusted party responsible for production, processing or operation should obtain the administrative permits stipulated by relevant laws and regulations (where applicable).
2) Not listed as a seriously untrustworthy entity in the National Enterprise Credit Information Publicity System and Credit China.
3) Within five years, no organic product or organic conversion certification certificates have been revoked due to providing false information, using prohibited substances, exceeding the scope of labeling, or major quality and safety incidents; within one year, no organic product certification certificates or organic conversion certification certificates have been revoked by the certification body for other reasons.
4) Provide the environmental quality monitoring (inspection) report or monitoring (inspection) conclusion of the place of origin within the validity period;
5) It is required to commit that the same batch of products will not be repeatedly certified by two (inclusive) or more certification bodies at the same time.
II. The entire on-site inspection process is fully controllable.
1. Appoint inspectors
For the same production unit or processing site of the same certification client, a certification body shall not assign the same inspector to carry out inspections for more than three consecutive years (including three years).
2. Origin Environment
The time of the water processing test report should not be earlier than 12 months before the inspection date, and the time of other types of monitoring (testing) reports should not be earlier than 24 months before the inspection date.
3. Inspection Process
When inspecting the production and processing procedures, products and premises, the certification history of the premises should be verified.
2) The calculation of the output and sales volume of certified products should be based on industry standards, the actual situation of the enterprise, and material balance principles. The product output should be reasonably calculated, and the calculation process should be clearly stated in the inspection report.
3) Clearly define the key points of the business certification inspection. In cases where there are storage facilities, the focus should be on whether the requirements for not altering the product packaging during both storage and transportation can be met.
4. Sample Testing
Sampling requirements: Products of the same type with the same ingredients and processing techniques but different specifications, forms, and processing accuracies. At least one high-risk final product should be tested.
2) If samples cannot be collected and sent for inspection before the certification certificate is issued, the certification body may only allow the certified organic products to be sold and promoted as organic products after they pass the inspection within the validity period of the certificate.
3) Product testing institution
The inspection and testing institutions should obtain the qualification accreditation (CMA), and the testing items should be within the scope of the qualification accreditation certificate. If the specific field laws and regulations do not stipulate that the legal qualifications should be obtained, the requirements of GB/T 27025 should be met. If the production and processing sites of the products are located outside the territory, they should comply with the requirements of ISO/IEC 17025.
5. Add termination checks
When any of the following situations occur, the inspection team shall report to the certification body and terminate the inspection upon its consent:
The client of the certification did not cooperate with the inspection activities, making it impossible to carry out the inspection.
2) There is a significant inconsistency between the actual situation of the certification client and the certification basis.
3) Other circumstances that prevent the completion of the certification process.
III. Organic Conversion Management Regulations
1) Production units that fail to maintain organic certification (including organic conversion) must go through the organic conversion process again to regain organic certification.
2) Organic conversion certificates will no longer be issued for processed products. Organic conversion certification certificates for processed products issued based on the old implementation rules will naturally expire upon their expiration dates.
3) If the planting has been continuously certified as organic abroad for four years and the breeding for two years, and the traceability proof complies with the requirements of GB/T 19630, the conversion period can be waived based on the results of the risk assessment.
IV. Strengthening Post-certification Management
1. Post-certification on-site inspection
Where the certificate is still valid but the certified organization no longer applies for certification continuously, the certification body shall arrange a post-certification on-site inspection, except in the following circumstances where on-site inspection is not required:
The certification certificate has been voluntarily cancelled by the certified organization and has been cancelled in a timely manner.
2) Where it is necessary to revoke the certification certificate;
3) During the validity period of the certificate, if the certification body is changed and the original issuing body receives the notice of acceptance of the change of the certification body.
2. Unannounced inspection
The certification body shall dispatch inspection teams directly to the site of the certified organization without prior notice. The certification body shall conduct unannounced on-site inspections of at least 5% of the certified organizations each year. For certified organizations that have not yet used the organic product certification mark, the proportion of unannounced inspections shall be no less than 10%, and at least one certified product shall be selected from each inspected certified organization for testing.
3. Tracking of Certified Products
For certified organizations that use the organic product certification mark, the certification body shall randomly select no less than 10% of the certified organizations each year and conduct tests on no fewer than one certified organic product from each selected organization in the circulation field.
4. Sales Certificates and Organic Code Control
The certified organization should associate the product traceability system with the organic code and sales certificate; the organic code shall not be issued to the certification entrustor who has only obtained the organic product operation certification.
V. Clarify the Format and Content of the Certificate
There are minor differences in the format requirements between the organic product certification certificate and the organic conversion certification certificate. You can refer to the certificate template. Please note that if the certificate has an attachment, both the certificate and the attachment must be used simultaneously for it to be valid.
All certified enterprises are requested to familiarize themselves with the 2025 version of the Organic Implementation Rules as soon as possible and improve their organic management in light of their own actual situations. The original text of the "Interpretation of the 2025 Version of the Organic Product Certification Implementation Rules" is attached for reference and study.
I. Detailed Requirements for Certification Application
When applying for organic product certification, the certification applicant must meet the following requirements:
1) Obtain legal business qualifications. The certifying client and the entrusted party responsible for production, processing or operation should obtain the administrative permits stipulated by relevant laws and regulations (where applicable).
2) Not listed as a seriously untrustworthy entity in the National Enterprise Credit Information Publicity System and Credit China.
3) Within five years, no organic product or organic conversion certification certificates have been revoked due to providing false information, using prohibited substances, exceeding the scope of labeling, or major quality and safety incidents; within one year, no organic product certification certificates or organic conversion certification certificates have been revoked by the certification body for other reasons.
4) Provide the environmental quality monitoring (inspection) report or monitoring (inspection) conclusion of the place of origin within the validity period;
5) It is required to commit that the same batch of products will not be repeatedly certified by two (inclusive) or more certification bodies at the same time.
II. The entire on-site inspection process is fully controllable.
1. Appoint inspectors
For the same production unit or processing site of the same certification client, a certification body shall not assign the same inspector to carry out inspections for more than three consecutive years (including three years).
2. Origin Environment
The time of the water processing test report should not be earlier than 12 months before the inspection date, and the time of other types of monitoring (testing) reports should not be earlier than 24 months before the inspection date.
3. Inspection Process
When inspecting the production and processing procedures, products and premises, the certification history of the premises should be verified.
2) The calculation of the output and sales volume of certified products should be based on industry standards, the actual situation of the enterprise, and material balance principles. The product output should be reasonably calculated, and the calculation process should be clearly stated in the inspection report.
3) Clearly define the key points of the business certification inspection. In cases where there are storage facilities, the focus should be on whether the requirements for not altering the product packaging during both storage and transportation can be met.
4. Sample Testing
Sampling requirements: Products of the same type with the same ingredients and processing techniques but different specifications, forms, and processing accuracies. At least one high-risk final product should be tested.
2) If samples cannot be collected and sent for inspection before the certification certificate is issued, the certification body may only allow the certified organic products to be sold and promoted as organic products after they pass the inspection within the validity period of the certificate.
3) Product testing institution
The inspection and testing institutions should obtain the qualification accreditation (CMA), and the testing items should be within the scope of the qualification accreditation certificate. If the specific field laws and regulations do not stipulate that the legal qualifications should be obtained, the requirements of GB/T 27025 should be met. If the production and processing sites of the products are located outside the territory, they should comply with the requirements of ISO/IEC 17025.
5. Add termination checks
When any of the following situations occur, the inspection team shall report to the certification body and terminate the inspection upon its consent:
The client of the certification did not cooperate with the inspection activities, making it impossible to carry out the inspection.
2) There is a significant inconsistency between the actual situation of the certification client and the certification basis.
3) Other circumstances that prevent the completion of the certification process.
III. Organic Conversion Management Regulations
1) Production units that fail to maintain organic certification (including organic conversion) must go through the organic conversion process again to regain organic certification.
2) Organic conversion certificates will no longer be issued for processed products. Organic conversion certification certificates for processed products issued based on the old implementation rules will naturally expire upon their expiration dates.
3) If the planting has been continuously certified as organic abroad for four years and the breeding for two years, and the traceability proof complies with the requirements of GB/T 19630, the conversion period can be waived based on the results of the risk assessment.
IV. Strengthening Post-certification Management
1. Post-certification on-site inspection
Where the certificate is still valid but the certified organization no longer applies for certification continuously, the certification body shall arrange a post-certification on-site inspection, except in the following circumstances where on-site inspection is not required:
The certification certificate has been voluntarily cancelled by the certified organization and has been cancelled in a timely manner.
2) Where it is necessary to revoke the certification certificate;
3) During the validity period of the certificate, if the certification body is changed and the original issuing body receives the notice of acceptance of the change of the certification body.
2. Unannounced inspection
The certification body shall dispatch inspection teams directly to the site of the certified organization without prior notice. The certification body shall conduct unannounced on-site inspections of at least 5% of the certified organizations each year. For certified organizations that have not yet used the organic product certification mark, the proportion of unannounced inspections shall be no less than 10%, and at least one certified product shall be selected from each inspected certified organization for testing.
3. Tracking of Certified Products
For certified organizations that use the organic product certification mark, the certification body shall randomly select no less than 10% of the certified organizations each year and conduct tests on no fewer than one certified organic product from each selected organization in the circulation field.
4. Sales Certificates and Organic Code Control
The certified organization should associate the product traceability system with the organic code and sales certificate; the organic code shall not be issued to the certification entrustor who has only obtained the organic product operation certification.
V. Clarify the Format and Content of the Certificate
There are minor differences in the format requirements between the organic product certification certificate and the organic conversion certification certificate. You can refer to the certificate template. Please note that if the certificate has an attachment, both the certificate and the attachment must be used simultaneously for it to be valid.
All certified enterprises are requested to familiarize themselves with the 2025 version of the Organic Implementation Rules as soon as possible and improve their organic management in light of their own actual situations. The original text of the "Interpretation of the 2025 Version of the Organic Product Certification Implementation Rules" is attached for reference and study.
Click the link to view the official interpretation of the "Organic Product Certification Implementation Rules" (2025 version) on the CNCA official website (in Chinese language).
For more information on related certifications, please contact:
Cotecna Kaixin Agriculture Certification Department
Email: Hua.SHAO@cotecna.com.cn
Mobile: +86 15901007200
About Cotecna Kaixin Certification
Beijing Cotecna Kaixin Certification Co., Ltd. ("BCK") is a third-party certification body accredited by CNAS and ANAB. Focusing on providing certification services covering quality and safety, agri-food products, intellectual property, information security, energy, and sustainability, we have served over 20,000 clients, and remains committed to delivering premium and efficient service to clients, contributing to economic prosperity, environmental sustainability, and social responsibility.