GLOBALG.A.P. Chain of Custody Implementation for Better Supply Chain Integrity

GLOBALG.A.P. Chain of Custody implementation

With food fraud and integrity issues presenting a growing challenge for the sector, the GLOBALG.A.P. Advisory Board opted to strengthen the GLOBALG.A.P. system by requiring the strict implementation of the GLOBALG.A.P. Chain of Custody (CoC) standard from 2023.

Deadline approaching

From 1 January 2023, all parties who handle loose, unpacked products originating from GLOBALG.A.P. certified production processes, as well as all parties who pack and label products with a GLOBALG.A.P. identification number (e.g., GGN, CoC Number, etc.) or make a written claim that a product originates from a GLOBALG.A.P. certified production process, are required to have valid CoC certification.

After this date, GLOBALG.A.P. will reserve the right not to conduct a full investigation on traceability problems or maximum residue level exceedances connected to products with a GLOBALG.A.P. claim if the supply chain in question does not have full CoC certification at every step.

Impact

  • This mostly affects companies with no agricultural/aquaculture production who trade, pack, and market products sourced from GLOBALG.A.P. certified production processes. As before, producers selling only the products included on their Integrated Farm Assurance (IFA) certificate do not need to implement the CoC standard.
  • For certain cases where it may be difficult to implement the CoC standard by this date, temporary exceptions will be in place until December 2023. Please see the section below for further details of this transition period.
  • CoC certification has the benefit of increasing transparency throughout supply chains, lowering the risk of food fraud, and enabling brands and retailers to act swiftly if problems arise.


Transition and implementation deadlines 2022–2023

According to the CoC general regulations, CoC certification can only be achieved if all suppliers have certified production processes. We understand the potential challenges of achieving certification for the entire supply chain at the same time or in a complete downstream sequence, therefore GLOBALG.A.P. has decided to offer a temporary implementation period which allows for some exceptions until 31 December 2023.

Within this timeframe, a downstream company will be able to achieve CoC certification even if part of the supply chain is not yet certified.

This is possible if the noncertified suppliers are:

  • Traders/Brokers:
    • Without physical possession of products or
    • With physical possession of packed and labeled products only
  • Companies storing, packing, and/or labeling products that originate from production processes are already certified to a GFSI recognized post-farm certification scheme, IFS (IFS Food, IFS Broker, IFS Cash and Carry, IFS Wholesale and IFS Logistics) or the QS Wholesale Fruit, Vegetables, Potatoes Standard (QS-System Bündler)

Together with the application for initial CoC certification, the company must provide the certification body (CB) with the following documentation.
A. Requirements for the company seeking exemption during initial CoC certification (Company A).

These documents must be presented for CB evaluation during the initial audit:

  1. Evidence of sending a letter/email to all suppliers requiring them to achieve CoC certification before the date of Company A’s recertification audit, or within 12 months from the date of the letter/email (whichever is earlier). There should be evidence of commitment by the supplier(s) to achieve CoC certification and acceptance of an audit by Company A’s CB or GLOBALG.A.P. in case of a claim investigation.
  2. Company A must have a suppliers list with information about the IFA/CoC certification status of every supplier.
  3. Company A must have documented information about the traceability of the products through the noncertified production part of the chain.
  4. Evidence that the company involved in storing, packing, and/or labeling certified products has a valid GFSI-recognized post-farm certification scheme, IFS (IFS Food, IFS Broker, IFS Cash and Carry, IFS Wholesale and IFS Logistics) or QS Wholesale Fruit, Vegetables, Potatoes Standard (QS-System Bündler) certification.
B. Requirements for the suppliers without certification:
  1. Registration with an approved CB as per CoC general regulations part I, section 4.2 (The CB registers the company in the GLOBALG.A.P. IT systems and assigns a CoC Number (status ‘accepted’ in the GLOBALG.A.P. IT systems)).
  2. Signed commitment with the CoC client and with the CB to have the certification audit conducted before the date referred to under section A.1.

Once in possession of this documentation, the CB may grant certification to the company even if not all suppliers have CoC certification. This exemption only applies for initial audits conducted before 31 December 2023.

Reducing duplication with industry collaboration

Since 2015, GLOBALG.A.P. has been collaborating with IFS (International Featured Standards) and BRCGS (Brand Reputation through Compliance Global Standard) to offer ““CoC through IFS” and “CoC through BRCGS” certification options that reduce the duplication of requirements. These options will remain valid in the future.

Quicklinks

CoC implementation guide
A flowchart to help you determine if you are affected by the new rules

Contact us

If you have any questions about the CoC standard or its implementation, please email  standard_support@globalgap.org