Organic Co-Packer Due-Diligence Guide
Use this guide to organize questions about an organic co-packer's certification scope, documented handling procedures, records, communication, and commercial fit. It is educational information, not a certification, compliance, or supplier-qualification decision.
- ✓ Clarify the product, handling activity, and certificate scope relevant to your relationship.
- ✓ Discuss documented handling, segregation, cleaning, storage, and change procedures appropriate to your products and agreement.
- ✓ Define the records, handoffs, and follow-up questions your team needs to manage.
Clarify the Product and Handling Scope
Start with the intended product, handling activity, ingredients, process, packaging, and commercial relationship. Except for limited exemptions, operations that handle products represented as organic generally must be certified, but the specific certificate and scope to review depend on the operation and activity. Discuss the relevant documents and questions with the co-packer, its certifier, and your advisers. See the USDA certification overview and 7 CFR 205.100.
Review Documented Organic Handling Procedures
Discuss the documented handling, segregation, cleaning, storage, and change procedures relevant to your products, contract, certifier guidance, and risk profile. Certified organic handlers must implement measures necessary to prevent commingling of organic and nonorganic products and protect organic products from contact with prohibited substances, but this guide does not prescribe an audit method or determine whether a procedure is adequate. See 7 CFR 205.272.
Define Records and Change Communication
Identify the records, evidence handoffs, change notifications, and exception communication your team needs for the relationship. Certified operations maintain applicable production, handling, and audit-trail records, but one checklist, CoA, or lot record does not by itself determine organic or other regulatory compliance. Review the operation's procedures with the appropriate parties and consult 7 CFR 205.103 for the certified-operation recordkeeping rule.
Use the Worksheet for Internal Follow-Up
Use the Organic Co-Packer Review Worksheet to organize your team's internal follow-up items. It counts your selected review statuses only; it does not determine certification, qualification, compliance, risk, or supplier selection.
This guide is educational information, not a certification decision, audit, organic-system-plan review, legal or regulatory advice, or a substitute for your certifier, contracts, or required procedures.
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This guide reflects workflows Guidance is being designed to connect. The commercial rebuild is being validated with CPG design partners and is not available for live demonstrations today.
Apply as Design Partner →Frequently Asked Questions
Why use an organic co-packer due-diligence guide?
A guide can help a brand organize questions about scope, documents, handling procedures, records, and communication. It does not determine certification, compliance, or supplier qualification.
How should a brand choose a review cadence?
Set a cadence that reflects the brand's contract, product and process changes, issues, certifier guidance, and approved procedures. This guide does not prescribe a universal audit schedule.
What can incomplete co-packer review create?
Poorly defined expectations or incomplete records can create operational, commercial, and certification risk. Consequences depend on the facts, contract, certification scope, and applicable requirements.
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