Abstract: The General Office of the State Administration for Market Regulation (SAMR) issued the Notice on the Interpretation of the 2025 Edition of the Implementation Rules for Organic Product Certification (hereinafter referred to as the "Interpretation") on December 26, 2025.

To prevent some enterprises from insufficiently understanding the Interpretation and causing disruptions to the certification process, the changes between the Interpretation and previous practices are summarized as follows:

Ⅰ.Changes to the Application Process(Corresponding to Clauses 5.2.2 and 5.2.7(8) of the Interpretation) 

1）The certification client has established and implemented a management system in compliance with GB/T 19630 Organic products – Requirements for production, processing, labeling and management systems, which must be effectively operated for at least three months. 

a) This clause requires you to establish a management system consistent with your actual production in accordance with the requirements of Chapter 7 “Management System” of GB/T 19630, and to effectively operate such system in full compliance with its own requirements for at least three months after establishment.

b) It should be noted that “effective operation” means not only that your management system is consistent with actual operations and fully covers all requirements specified in Chapter 7 “Management System” of GB/T 19630, but also that you possess legal operation and/or production rights for the products to be certified before operating the system. For example:

·For activities falling under the scope of the Food Production License, you may legally operate your system only after obtaining the Food Production License;

·For activities falling under the scope of livestock and poultry breeding, you may legally operate your system only after obtaining the corresponding Animal Epidemic Prevention Condition Certificate.

c) In light of the above requirements, after you submit your certification application, our institution will verify whether your management system has been effectively operated for at least three months based on the submitted management system documents, supporting qualifications, records and other relevant materials

a) For initial certification applications, this clause requires you to provide a production area environmental quality monitoring (testing) report or monitoring (testing) conclusion at the time of application.

b) For recertification, although you already hold a compliant production area environmental quality monitoring (testing) report or conclusion, you shall pay attention to the validity period of such documents. For example:

The date of processing water testing reports shall not be earlier than 12 months prior to the inspection date;

The date of other monitoring (testing) reports shall not be earlier than 24 months prior to the inspection date.

c) For certification clients with production units located within Chinese territory, the corresponding testing reports (or conclusions) shall be issued by testing and inspection institutions with statutory qualification, i.e., your reports shall be stamped with the CMA qualification mark.

d) For certification clients with production units located outside China, equivalent production area environmental quality monitoring (testing) reports or conclusions shall be provided. When entrusting testing to overseas laboratories, you shall select testing and inspection institutions that comply with ISO/IEC 17025 requirements.

Ⅱ.Changes to Recertification and Post‑certification Supervision Processes(Corresponding to Clauses 6.1 and 6.2 of the Interpretation) 

For certified organizations applying for continuous organic product certification, such inspection may be carried out in conjunction with recertification. The specific implementation is as follows:

a) This clause mandates that certification bodies conduct at least one on-site post-certification inspection each year (i.e., after you obtain the certificate). Such inspection may be conducted together with the recertification inspection. Therefore, for enterprises maintaining continuous certification with our institution, your post-certification on-site inspection may be carried out in conjunction with the recertification inspection.

b) For organizations not applying for continuous organic product certification, our institution will also conduct one post-certification inspection within the validity period of the certificate in accordance with the Interpretation, unless you voluntarily submit an application for certification cancellation within two months prior to the certificate expiration date or provide an acceptance notice issued by the certification body you intend to switch to. If either condition is met, our institution may waive the post-certification on-site inspection.

c) For those who neither apply for voluntary cancellation nor cooperate with on-site inspections, our institution will promptly notify you by email and/or message of potential consequences including the suspension and revocation of your certification certificate.

d) For production activities with multiple growing seasons (e.g. leafy vegetables), at least one additional post-certification on-site inspection will be arranged separately, which shall not be combined with recertification.

e) Unannounced on-site inspections shall be conducted for at least 5% of certified organizations each year. A new sampling requirement is added for organizations that have not yet used the organic logo, with a sampling ratio of no less than 10%.

f) Sampling and testing of products bearing the organic logo shall be conducted in the circulation sector each year, with a sampling ratio of no less than 10%, and at least one product per certified organization shall be inspected.

Conclusion

All certified enterprises are requested to assess the impacts arising from these changes in light of their actual conditions.

The full text of the Interpretation is attached hereto for reference and study.