Canadian Food Inspection Agency peer review report on Mexico's organic system – 2025

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Abbreviations and special terms used in this report

AB
Accreditation Body
CA
Competent Authority
COR
Canada Organic Regime
CB
Certification Body
CFIA
Canadian Food Inspection Agency
CNPO
General Directorate of Agrifood Normalization
COFEMER
Federal Commission for Regulatory Improvement (Comision Federal de Mejora Regulatoria)
EMA
Mexican Accreditation Entity (Entidad Mexicana de Acreditacion)
EU
European Union
GPO
Organized Producer Groups
LPO
Law for Organic Products
LOOAA
Mexican Guidelines for the Organic Operation of Agricultural and Livestock Activities, 2013 Agreement through which the Guidelines for the Organic Operation of the agricultural and livestock activities are made public.
CMOEA
Canada – Mexico Organic Equivalency Arrangement
NOP
National Organic Program (USDA)
NC
Non-Conformity
PROFECO
Federal Consumer Protection Office (Procuraduria Federal del Consumidor)
PSL
Permitted Substances List
RLPO
Mexican Regulations for the Organic Products Law (RLPO), 2010
SFCR
Safe Food for Canadians Regulations
SAGARPA
Secretariat of Agriculture, Livestock, Rural Development, Fisheries and Food
SENASICA
The National Service of Health, Food Safety and Quality (Servicio Nacional de Sanidad, Inocuidad y Calidad Agroalimentaria)
SIAP
Agri-Food and Fisheries Information Service (Servicio de Informacion Agroalimentaria y Pesquera)
USDA
United States Department of Agriculture

Executive summary

This report summarizes observations made during the Canadian Food Inspection Agency (CFIA)'s March 2025 peer review of the Mexican Organic Program.

The objective of the peer review was to determine the extent to which the Mexican competent authority, Servicio Nacional de Sanidad, Inocuidad y Calidad Agroalimentaria (SENASICA) demonstrates conformity with the requirements specified in the Canada – Mexico organic equivalency arrangement (CMOEA).

The assessment was conducted from March 18 to March 26, 2025. It included meetings with the competent authority (SENASICA), the Accreditation Body (AB) EMA, two Certification Bodies (CBs), two primary production units including one farm and one greenhouse, and one cooling/storage/distribution facility.

The key elements of the assessment included:

  • 1) Authorities
    • Current legislative authorities for organic products, including regulations, standards, codes of practice, and arrangements. In particular:
      • authority to recognize and accredit parties involved in the Mexican Organic Program
      • authority to carry out monitoring and surveillance activities
      • authority to respond to non-compliances where risk has been identified (for example: recalls, other control and enforcement activities)
  • 2) Government organization and resources
    • The roles and responsibilities of the various government departments and authorities involved in the Mexican organic program
    • The resources, responsibilities, functions, and coordination between the parties involved in the Mexican organic program
    • Resources and competencies of the parties involved in the delivery of the Mexican organic system
  • 3) Third parties involved in the implementation of the Mexican organic program
    • Organizations responsible for the implementation of the Mexican Organic Program and their relationship with SENASICA.
  • 4) Enforcement and surveillance activities
    • The role of SENASICA, EMA and the CBs in organic product inspections, surveillance, and enforcement activities.

The peer review determined that SENASICA has implemented a control system for the certification of organic operators that is supported by good collaboration between SENASICA, EMA, and the CBs.

This system guarantees that agricultural organic products certified under Mexico's Organic Regulations exported and marketed in Canada meet the terms of the CMOEA.

This report provides a list of findings which highlight opportunities for improvement and enhancement of the implementation of Mexico's organic system.

The observations and recommendations contained in this report are based on information provided to the peer review team through the Canadian peer review questionnaire, personal interviews, and on-site observation. They represent the collective understanding of the peer review team.

1. Background

Canada and Mexico began working towards establishing an equivalency arrangement to facilitate organic trade between the two countries in 2014. The initial and the most recent onsite assessment of Mexico's organic system took place in March 2018.

The Canada-Mexico Organic Equivalency Arrangement (CMOEA) came into effect on February 15, 2023. This arrangement applies to agricultural and processed products of plant origin grown or produced within either country, livestock and livestock products produced in Canada, and organic products whose final processing or packaging occurs within either country.

As per the conditions of the arrangement, and following advance notice from the CFIA, SENASICA agreed to accommodate the CFIA's request to conduct an on-site peer review to verify how SENASICA is implementing the requirements of the Mexican organic system.

2. Objectives of the on-site assessment

The objective of the peer review was to determine the extent to which SENASICA demonstrated conformity with the requirements specified in the CMOEA.

3. On-site assessment criteria

The following references were used during the on-site assessment:

  1. Terms of the CMOEA
  2. CFIA peer review procedure related to the Canada Organic Regime (COR)
  3. The Mexican Guidelines for the Organic Operation of Agricultural and Livestock Activities (LOOAA), 2013
  4. The Mexican General Rules for Use of the National Seal, 2013
  5. The Mexican Regulations for the Organic Products Law (RLPO), 2010
  6. The Mexican Organic Products Law (LPO), 2006
  7. SENASICA procedure to carry out periodic inspections to approved organic products certification agencies
  8. SENASICA procedure for the approval of certification bodies of organic products
  9. ISO 17011:2017
  10. ISO17065:2012

4. On-site assessment protocol

The CFIA's peer review team planned and conducted the peer review in a manner which allowed the team to obtain sufficient information to confirm the observations and conclusions. The peer review opened on March 12 and 13, 2025 with a virtual meeting with the General Directorate of Agri-Food Standardization (SAGARPA); the National Service of Health, Food Safety and Quality (SENASICA); the Federal Consumer Protection Office (PROFECO); and the Mexican Accreditation Entity (EMA).

The on-site peer review was conducted in accordance with CFIA peer review procedure related to the Canada Organic Regime (COR). From March 19 through to March 25, 2025, the peer review team visited an organic berry farm, an organic berry cooling/distribution/ storage facility, an organic greenhouse operation, and the headquarters of two CBs.

The on-site portion of the peer review then concluded with a closing meeting on March 26, 2025.

As part of the peer review, the CFIA peer review team reviewed each level of Mexico's organic system (administration, accreditation, certification, and production) to confirm that the responsible authorities have the necessary controls in place to ensure compliance with the LPO. In doing so, the team:

  • met with representatives from SENASICA to review the administration of the organic system and to discuss the roles and responsibilities of the various parties involved in the system
  • met with representatives of EMA to discuss their involvement in the accreditation of CBs involved in the Mexican organic system
  • met with representatives from two CBs to review their certification processes and procedures
  • witnessed three scheduled inspections conducted by CB inspectors at organic operations to:
    • observe the production, handling, and labelling of organic foods,
    • to determine the level of compliance with Mexican requirements for organic production, and
    • to confirm their knowledge of the Mexican organic system and the terms of the CMOEA
  • observed three witness audits conducted by SENASICA staff

5. Overview of the Mexican organic sector

As of the peer review in March 2025, Mexico had 326 068 hectares of organic land. Additionally, there were 62 453 certified organic producers. Chiapas is the leading state for organic production with the main organic commodities being coffee, honey, and cocoa.

5.1 National legislation and national standards

Mexico's organic control system is based on the following pieces of legislation:

  1. Organic Products Law (LPO), 2006
  2. Regulations for the Organic Products Law (RLPO)
  3. Agreement through which the Guidelines for the Organic Operation of the agricultural and livestock activities. (LOOAA), 2013
  4. The General Rules for Use of the National Seal and the general rules for its use in the labelling of certified organic products, 2013
  5. National list of substances allowed for the Organic Operation of the agricultural and livestock activities, of the diverse by which the Guidelines for the Organic Operation of Agricultural Activities are disclosed, 2013.

These regulations can be found on the Gobierno de México website.

6. Implementation of the Mexican organic program

The Mexican organic control system covers the activities performed by operators at all stages of the production, preparation and distribution chain from farm to fork. Operators are free to choose any of the 20 CBs approved by SENASICA to offer certification services in Mexico. The CBs are approved by SENASICA and supervised by both SENASICA, EMA, and the foreign ABs. The CBs charge operators a fee for their certification services.

In addition, there are several government organizations that play important roles in the implementation and the enforcement of Mexico's organic regulations.

6.1 SENASICA organic team

The competent authority (CA) for organic production in Mexico is SENASICA. SENASICA is the department within the Ministry of Agriculture (SAGARPA) that is responsible for the oversight of the organic program in Mexico.

SENASICA's department of organic regulation and operation is responsible for:

  • implementing organic production legislation
  • authorizing and inspecting the approved CBs
  • addressing complaints and pesticide presence in organic products
  • collaborating with national and foreign authorities on compliance and monitoring

Under this department there are two departments that share the oversight of the organic program. The first department is called the department of Input of Organic Products which is responsible for updating the National List of Substances for Organic Production. Under this department, there are four (4) specialists, and four (4) technical support staff involved in inspection, surveillance, and agro-food ruling for organic operations.

The second department is the department of Organic Regulation and Operation which is responsible for the coordination of the actions of the National Control System for organic products, updating legal provisions, managing international equivalence, and overseeing inspection and surveillance processes.

SENASICA's staff involved in Mexico's organic program delivery maintains its competence by participating in various trainings:

  • Mandatory Training: Career public servants must complete 40 hours of mandatory training to develop, complement, perfect, or update the knowledge and skills necessary for their positions.
  • Specific Training Programs: SENASICA offers specific training in various technical subjects, including agricultural training, human rights, and data protection.
  • Internal Training Dynamics: After each surveillance inspection, presentations of the results are organized to share observations and best practices.

The CFIA peer review team focused on SENASICA's role in the accreditation and approval of the CBs as well as the surveillance activities conducted by SENASICA, import controls, and controls on labelling and marketing of organic products.

6.2 Mexican Accreditation Entity (EMA)

The Mexican Accreditation Entity (EMA) was established in 1999 and has been a member of International Accreditation Forum since 2004. EMA has the authority to grant accreditations to laboratories, verification units, and CBs based on the applicable standards. EMA serves as an accreditation body (AB) under the Mexican Regulations. EMA accredits the CBs whereas SENASICA approves them.

EMA's main organic-associated tasks are to:

  • grant accreditation of CBs to ISO 17065 standard
  • suspend or withdraw accreditation of CBs
  • oversee the accredited CBs

Currently, there are 12 CBs directly accredited by EMA.

EMA involves SENASICA staff as technical experts when reviewing the CB application and when accreditation decisions are made.

6.3 Federal Consumer Protection Office (PROFECO)

The objective of the Federal Consumer Protection Office (PROFECO) is to monitor and verify that companies marketing organic products comply with the Federal Consumer Protection law and its Regulations. PROFECO develops monitoring programs for suppliers that market organic products including national and imported products. PROFECO also follows up on complaints received from consumers.

If the organic product is found to be non-compliant, the CB and the operator work together to address the complaint and relabel the product. In some cases, the product can be removed from the market.

PROFECO notifies SENASICA of actions taken on organic products.

In 2024, there were only 4 complaints received. This may be attributed to SENASICA's market surveillance efforts.

6.4 Certification Bodies (CBs)

Currently, under Mexico's organic system there are 20 CBs that are approved by SENASICA to conduct certification activities. 12 of the CBs are accredited by EMA and 8 CBs are accredited by foreign ABs such as DAkks, CAEQ, Accredia, and IOAS.

CBs are responsible for:

  • conducting annual and risk-based inspections
  • input verification
  • issuing organic certificates
  • issuing sanctions in accordance with the agreed upon sanction catalogue
  • following up on complaints and notifications from competent authorities

The list of approved CBs is publicly available on SENASICA's (Spanish only) website.

6.5 Certified organic operators

In 2025, there were 62 453 certified organic producers which include grower groups and individual operators. They vary in size, complexity, and market scope such as whether they import and/or export.

7. Administration of the Mexican organic program

7.1 Accreditation and approval of CBs

CBs in Mexico are approved by SENASICA as per Article 19 of RLPO. Accreditation to ISO 17065 is one of the conditions for approval of the applicant CB.

EMA's accreditation process consists of application review, on-site office audit, and witness audit. SENASICA technical experts are invited to participate in the application review and the decision-making process.

The timing for addressing any non-conformity (NC) depends on the nature of the issue but is typically 45 days following the audit. For the surveillance audits, the CB is given 30 working days to address NCs. Failure to address the NCs may result in suspension or cancellation.

It was confirmed that EMA assesses the certification activities implemented by the CBs through an annual on-site office audit. A witness audit is conducted subsequently during the surveillance cycle.

In addition to the accreditation process completed by EMA, SENASICA also approves the CBs under the Mexican Organic System.

SENASICA relies on the accreditation bodies such as DAkks, Accredia, CAEQ to accredit CBs in other countries. SENASICA approves all CBs.

SENASICA has developed a portal for CB approval where the applicant is required to upload the documentation. The approval is based on a checklist developed by SENASICA which covers 20 different requirements.

SENASICA does not sign any agreement with the approved CBs; however, a document confirming that that the approval is valid for 5 years is issued.

The CFIA peer review team noted that the CBs are not approved for any geographical scope. According to SENASICA there are 26 countries in which the CBs can certify to LPO; however, it is not clear how the CBs' activities in these countries are monitored and assessed.

SENASICA clarified that as part of its oversight of CBs and certification activities in other countries, SENASICA requires the submission of annual and monthly reports on certification activities. It also monitors the response to observations issued by Accreditation Entities to CBs and verifies product traceability based on risk.

7.2 Surveillance of the CBs

The surveillance of the CBs is conducted by both their AB and SENASICA. In 2015, a matrix for accreditation and approval was implemented to minimize any duplication of work by SENASICA and EMA. The CFIA peer review team noticed that SENASICA and EMA still have some overlapping in the surveillance activities they conduct such as office audits and witness audits. The CFIA peer review team did not have sufficient time to review how the international ABs conduct the CB's surveillance activities.

SENASICA commented that SENASICA has a regulatory framework, functions, and procedures independent of those of the ABs. It must complete the evaluation, approval, and oversight stages, given that accreditation is a requirement for approval to certify LPO.

Likewise, the ABs, not just the EMA, carry out all phases of their evaluation and ruling process independently of SENASICA.

Therefore, some stages carried out by SENASICA appear to overlap with those of the ABs.

While the EMA's annual surveillance activities focus on compliance to ISO 17065, SENASICA's annual surveillance audit examine the implementation of the Mexican Guidelines for the Organic Operation of Agricultural and Livestock Activities (LOOAA), such as risk assessment, risk-based planning of inspections, effective management of complaints, and positive chemical residues.

EMA's annual surveillance activities are conducted through on-site office and one witness audit per accreditation cycle.

SENASICA carries out annual surveillance activities on CBs by using their own tools to record their observations. The checklists used by SENASICA for the witness audit focus on the certification process and verifies the documentation used by the CB.

On average, the duration of SENASICA's surveillance audit, including the witness audit, is one week. The number of witness audits depends on the number of operators and type of certified products. There is no written procedure to determine the number of witness audits to be conducted.

SENASICA commented that their surveillance inspections include inspections at the CB offices, as well as one or more field attestation sessions (witness audits) based on the risk analysis conducted in preparation for the inspection.

SENASICA maintains an Excel database that classifies the risk level of the CBs and records operations identified as high risk, which must be scheduled for witness audits.

CB inspections and the witness audits are scheduled based on the "Risk Matrix" provided by Excel, to verify critical points in the implementation of the LPO, for example, monitoring of prohibited substances, traceability, and mass balance.

Although CFIA confirmed with SENASICA that the SENASICA inspectors do not share their observations with the CB inspector during the witness audit, the CFIA peer review team noted that after all SENASICA's witness audits SENASICA shared their findings/comments with the CB inspector at the closing meeting.

At the end of SENASICA's inspections at the CBs, an exit report is left with the CB. Five days are given to the CB to agree/address the observations and 20 business days to resolve the NCs.

Although the suspension process is not specified in the Organic Law, there are technical guidelines for suspension and cancellation. EMA has procedures in place for the suspension and cancellations of CBs which is publicly available on their website. If EMA decides to suspend or cancel a CB's accreditation, SENASICA will also suspend or cancel their approval.

CBs are required to submit monthly and annual reports to SENASICA. These are used to prepare SENASICA's surveillance visits, and to assess the overall performance of the CBs and the CB inspectors. The reports contain information such as the list of certified operators, their monthly inspection program, the list of voluntary withdrawals, suspended or cancelled operators, and the number of chemical residue samples taken.

SENASICA clarified that currently, the monthly and annual reports are processed only by SENASICA and serve two purposes: 1) to integrate the risk analysis database to prepare for surveillance visits and evaluate the overall performance of the CBs and their inspectors, and 2) to publish the Organic Operations Dashboard

7.3 CB's compliance with SENASICA's organic requirements

7.3.1 CB's organisation and resources

The CFIA peer review team visited the headquarters of two CBs accredited to certify to multiple standards including Mexico' organic standard. They are adequately resourced and have invested resources to train their staff including inspectors. Both CBs are approved by SENASICA.

The CFIA peer review team confirmed that one CB is accredited by an international AB for more than one certification scheme and the other CB by EMA under the Mexican Organic Law and by another AB to other certification schemes.

The CFIA peer review team observed SENASICA's office inspections and witness audits on both CBs.

Usually, SENASICA's inspections on the CBs are scheduled for several days; however, for the purpose of the peer review, the office inspections were limited to one day.

There is a legal requirement for SENASICA to inspect the CBs which was confirmed by both CBs signing an appointment agreement. It is required that the exit report is signed by two witnesses.

Both inspections started with an opening meeting and review of the inspection plan, including a summary of the results from the witness audit and assessment of certain office activities.

The CFIA peer review team noted that the inspection checklists used by both CBs refer mainly to the USDA NOP certification requirements and very rarely to the LPO certification requirements.

Under Mexico's organic system, input review and verification should be done by the CBs. It was observed that many of the inputs are OMRI approved and have not been reviewed for more than 5 years. In addition, OMRI does not conduct input reviews under the LPO. SENASICA didn't make any note on this observation.

SENASICA clarified that the CBs must ensure that the inputs used in organic production are on the National List of Permitted Substances and have a Sanitary Registration issued by COFEPRIS. The Sanitary Registration is equivalent to the EPA registration.

The OMRI registration is another characteristic of the input; it is not a determining criterion for its use in production certified under the Organic Production Regulations (LPO); therefore, SENASICA did not provide any comments.

The CBs have this information and are aware that they are responsible for determining the use of inputs prior to or during the inspection, as well as verifying compliance with the criteria established in the Guidelines Agreement and the National List, in accordance with Article 40 of the Regulations of the Organic Products Law, Articles 20, 31, 235, 241, 246, 267 sections II and III, and 277 of the Guidelines Agreement.

In the case of one CB, the certification decision is made outside Mexico; however, it was not noted by SENASICA since SENASICA does not operate outside Mexico.

SENACICA clarified that the files of operators certified under LPO by CB personnel outside of Mexico can now be assessed remotely from Mexico.

After the office audits, the CFIA peer review team had an opportunity to interview representatives from both CBs and confirmed they have:

  • quality systems, procedures, and agile tools which comply with ISO 17065
  • inspection scheduling systems
  • certification processes, infrastructure, procedures and tools to deliver their certification activities effectively
  • procedures to ensure that on-site inspections are conducted by trained inspectors in accordance with clause 6.1.2 of ISO 17065
  • a formal performance monitoring process for the inspectors to identify gaps in training
  • a database with the list of inspector qualifications
  • regular trainings, workshops, and online activities to reinforce inspectors' knowledge of the Regulations and any new changes in the organic program
  • full-time and freelance inspectors who are rotated every 3 years

7.3.2 CB's certification process

The CFIA peer review team observed that in compliance with the Mexican certification requirements, the CBs put in place procedures to ensure that all the operators submit their updated organic plans before the expiration of the operator's certificate. If the inspection is not completed in time for justified reasons, the certificate can be extended for a period of up to three months.

Before the inspection is conducted, the CB prepares specific instructions for the inspector. These instructions can include follow-up on previously issued NCs, sampling etc. The duration of inspections varies depending on the nature and complexity of the farm and/or processing facility. Most of the inspections cover both LPO and NOP.

After completing the inspection, the inspectors have a specific timeframe within which an inspection report must be prepared and submitted to the CB. The inspection report and NCs are reviewed by the CB certification committee and the CB may decide to add or remove NCs as they deem fit. The CFIA peer review team observed that the categorization of and timelines to address the NCs vary between the two CBs. Additionally, SENASICA did not establish specific timeframes. Once the inspection is finalised and all NCs are addressed, the CB makes a certification decision, and each operator receives a certification document which confirms that the operator fulfils the requirements of the LOOAA.

The CFIA peer review team confirmed that in addition to the annual inspections, both CBs conducted additional 10% unannounced risk-based inspections. Both CBs had their own risk analysis tool based on criteria including type of propagation materials, positive tests, use of inputs, the nature and complexity of the operation, the number of clients etc. The additional inspections are based on the outcome of the risk assessment process or are random.

As part of the inspections, inspectors take samples according to the annual sampling plan developed by their CB. The CB inspectors are all trained to take samples and have a sampling kit available with them during inspections. CBs are required to report to SENASICA any results of positive detection of chemical residues. The CBs inform the operator of the positive results and requests follow-up actions. During the investigation, the product or affected production lot must be suspended from marketing. SENASICA reviews the actions taken by the operator to ensure that satisfactory follow-up was taken.

Under the Mexican regulations there are no specific requirements for grower groups in the LOOAA, Chapter 3. The CFIA peer review team observed that the CBs developed a risk analysis chart to determine the number of operators to be inspected each year. The SENASICA's guidelines for grower groups are not clear as the CBs are not in agreement on how these should be established.

SENASICA commented that the CBs need to apply the criteria established in Articles 221, 221 bis, 221 ter, 223, 224, and 2225 to determine the inspections to be conducted on Producer Groups. Additionally, SENASICA, together with the CBs, developed a guide to implementing criteria for the certification of grower groups. This guide is published on the SENSICA website to support the CBs' procedure.

The CFIA peer review team noticed good communication between the CBs and the operators. The CBs keep their operators informed of any new organic requirements or changes by issuing bulletins and through emails.

7.4 Certification and supervision of operators

The CFIA's peer review team witnessed CB inspections conducted by two different inspectors from two different CBs at a berry farm, a cooling and storage facility, and a vegetables greenhouse and packing facility.

A recommendation was given to SENASICA to ensure that relevant information about the observed operation such as inspection plan, current organic certificates, description of the company, when the last inspection was, as a minimum be shared with the CFIA peer review team in advance to facilitate the peer review process.

All CB inspections started with a brief opening meeting and a tour of the facility/farm, followed by review of relevant documentation (such as the organic plan, sanitary practices), input verification, traceability exercise, review of NCs from the last inspection, and finished with a closing meeting.

It was noted that not all observed CB inspectors explained to the operation the objective of the inspection and the organic standard against which they were inspecting.

It was noted that the inspectors used detailed checklists prepared by the CBs to record their observations.

The CB inspectors reviewed and verified the documentation for the transportation trucks including cleaning. It was confirmed that the transportation trucks come with the required documentation to be used for organic transportation. Both the drivers and the operators sign the declaration form. For each shipment received by the operator, a certificate is requested.

Overall, the three inspections of the operations that were witnessed by the CFIA peer review team were satisfactory. The inspectors are familiar with the standard and the Mexican organic requirements and followed the instructions given to them by their CB.

During one of the inspections the CB inspector had difficulties conducting the mass balance and the traceability exercise. The inspection took longer than anticipated as the CB inspector spent more time walking around the farm. The CFIA peer review team was not clear if the traceability exercise was completed at the end of the day.

At the closing meeting two of the inspectors left exit reports with the operations and clarified that the final certification decision is made by the CB.

In addition, the CFIA peer review team observed three SENASICA witness audits of the CB inspectors. SENASICA's inspector had a specific checklist to follow during the witness audits. The checklist differs depending on the type of operation (example: livestock, vegetable etc.) and is formulated as a yes or no response with comments.

It was noted that SENASICA auditors did not have an opening meeting with the CB inspector as is specified in ISO 19011, clause 6.4.2. to explain their role during the inspection.

After the inspection a closing meeting was held between the CB inspector and the SENASICA inspector to provide feedback on what was observed. The CFIA peer review team confirmed that SENASICA always prepares a witness audit report which is discussed and shared with the CB.

The CFIA peer review team had an opportunity to interview one of the CB inspectors. At the meeting, the following topics were covered: training taken by the Inspector, preparation for the inspection, sampling instructions from the CB and inspector's technical knowledge of the Mexican organic requirements.

7.5 Management of complaints

As the Administrator of the Organic Products Control System, SENASICA directly addresses complaints and reports related to:

  • the use of the term "organic" and the National Distinction on product labelling
  • certification processes or the issuance of certificates by organic authorities
  • complaints about organic operations filed by Organic Authorities

Complaints about the claim "organic" under LPO received by SENASICA are referred to the CBs to manage. SENASICA maintains a register for all the complaints and maintains a file for each complaint. SENASICA's complaint procedure on their website includes an email address which can be used for complaint submission. The 3 types of complaints are complaints about SENASICA's organic products, against SENASICA's approved CBs and to be referred to PROFECO. When SENASICA refers the complaint to a CB, the CB follows its own complaint procedure and informs SENASICA of the follow-up actions and end results.

SENASICA coordinates actions with Profeco to address complaints related to organic products at consumer points of sale and with Organic Authorities to address complaints about suspected contaminants or mislabeling of products.

7.6 Mexico import controls for organic products

Article 33 of the LPO requires all products coming to Mexico to be certified LPO or certified under an equivalency arrangement.

As per Mexican organic requirements all importers must be certified. When the importer is certified under LPO they can bring any organic product certified as organic under any other certification scheme only for marketing in Mexico.

Based on the LOOAA, ingredients used in multi-ingredient products must either comply with the Mexican Regulations or they must be imported from a country in which Mexico has an equivalency with. In addition, as per Article 212 of the LOOAA, the CBs re-certify imported organic products based only on document verification.

SENASICA maintains an internal database containing information on the countries of origin of imported organic products, points of entry into Mexico, and importer data.

This database allows for monitoring the sale of organic products in Mexico and addressing complaints filed in the domestic market. This database is for internal use because it is part of health controls at ports, airports, and borders.

8. SENASICA communication with EMA and CBs

The CFIA peer review team noted that the communication between the different parties involved in the implementation of Mexico's organic program is well established, open, and often a two-way dialogue.

SENASICA hosts an annual meeting with the CBs to discuss the performance of the CBs, changes to the Regulations, new requirements, and upcoming challenges.

9. Closing meeting

A closing meeting with representative of SENASICA was held at the SENASICA state office in Tlaquepaque, Guadalajara on March 26, 2025. During the meetingthe CFIA peer review teampresented a summary of their observations and recommendations. SENASICA had the opportunity to discuss the observations.

10. Overall conclusions

  • All parties involved in the peer review including staff at SENASICA, the CBs, EMA and the operators, were helpful, responsive, and accommodating to the CFIA peer review team during the visit.
  • SENASICA is knowledgeable and committed to further developing the existing organic system.
  • SENASICA has strong oversight over the CBs in Mexico.
  • EMA as a national accreditation body has an accreditation process based on ISO17011 which covers compliance verification activities of CBs in Mexico including headquarters and witness audits.
  • SENASICA staff have good collaboration with EMA and exchange information about the EMA accredited CBs.
  • The visited CBs are aware of the Canada-Mexico Organic Equivalency Arrangement, the export and labelling requirements for organic products going to Canada, and they expressed interest in further benefitting from the arrangement.
  • The CBs in Mexico are subject to regular inspections conducted by SENASICA. They are required to provide monthly updated reports regarding their certification activities which allows SENASICA to have a good understanding of the status of the operators.
  • The CB Inspectors observed by the CFIA peer review team conducted the inspections following the procedures established by their CBs.
  • The operators visited are committed to following and applying the organic production requirements, mainly for export. They are transparent and open about their production system.

11. Next steps

  1. SENASICA will be given opportunity to verify the content of the report for accuracy.
  2. The comments from SENASICA will be taken into consideration in the final report.
  3. The report will be made publicly available as it is part of the on-going monitoring of the existing equivalency arrangement for organic products between Canada and Mexico.
  4. SENASICA is requested to provide an update on the progress of the implementation of the recommendations within 60 working days from the receipt of the final report.

Annex A: Summary of the Canadian Food Inspection Agency (CFIA) findings from the assessment of Mexico's organic system (2025)

SENASICA provided responses to the CFIA peer review team findings listed in bullet point:

CFIA finding

SENASICA has approved 20 CBs. 12 are accredited by EMA while 8 are accredited by other accreditation bodies. SENASICA is directly involved in the work of EMA by participating in the application review and decision process. SENASICA is not involved in the work of the other accreditation bodies, for example CAEQ, DAkkS, Accredia.

SENASICA response

  • Regarding organic products, SENASICA currently only participates in initial accreditation evaluations with the EMA. Additionally, SENASICA participates in the Technical Opinion Committee.
  • In response to the CFIA's observation, SENASICA will coordinate actions with the ABs to participate in the initial accreditation evaluations of the CBs and in the surveillance evaluations with risk bases. In the first stage, participation will be remote, to strengthen the performance of the CBs in other countries.
  • SENASICA appreciates the observation and specifies that, considering that the CMOEA has a territorial scope and applies to products produced and processed in Mexico, compliance with the terms of this equivalence is ensured.

CFIA finding

SENASICA provides strong oversight over the CBs with physical locations in Mexico. However, it is not clear how they oversee the work of the CBs outside of Mexico. It's our understanding the CBs can work and certify products to the LPO in any country, however SENASICA doesn't go to other countries to conduct inspections.

SENASICA response

  • As part of SENASICA's oversight of CBs and their certification activities in other countries, it requires the submission of annual and monthly reports on certification activities. It also monitors the response to observations issued by Accreditation Entities to CBs, verifies the traceability of products based on risk, and maintains a database of imported organic products for follow-up in the event of complaints.
  • SENASICA ensures that all personnel involved in the process and making decisions regarding LPO certification in Mexico and other countries have the technical capacity and job profile for LPO certification. A copy of the personnel files is in the SENASICA archives.
  • The files of certified operators who were certified outside of Mexico under LPO certification can now be evaluated remotely, in accordance with Article 18, Section II c) of the Organic Regulations on Organic Products.

CFIA finding

Based on the limited review of the CBs files, the CFIA peer review team noted that not all accreditation bodies conduct the same number of surveillance and witness audits on CBs. For example, EMA informed the CFIA that they conduct one WA initially and one during the 5-year surveillance cycle.

SENASICA response

  • As part of SENASICA's oversight of CBs and their certification activities, SENASICA requests from CBs a copy of the observations issued by the Accreditation Entities to identify critical points, deficiencies, or improvements in the certification processes and monitor their resolution by the CBs.
  • In response to this observation, SENASICA will request from the ABs their CB surveillance program and the status of their accredited entities to coordinate collaborative actions.
  • It is noted that the EMA conducts annual surveillance of CBs and informs SENASICA of its annual surveillance program and the accreditation status of each CB. SENASICA may share the respective databases.
  • SENASICA appreciates the CFIA's observation. Furthermore, considering that the CMOEA signed between Mexico and Canada has territorial scope and applies to products produced and processed in Mexico, compliance with the terms of the CMOEA is ensured

CFIA finding

EMA's technical experts are approved by SENASICA. However, the experts of the other accreditation body are not approved by SENASICA.

SENASICA response

  • SENASICA appreciates the CFIA's observation and will verify that the profile, skills, and competencies of the personnel working in the ABs have the technical capacity to evaluate the LPO.

CFIA finding

Article 33 of the LPO requires all products coming to Mexico to be certified LPO or certified under an equivalency arrangement. However, any organic product certified to any certification scheme can be imported and marketed as organic in Mexico if the importer is certified. CFIA will provide this product name and request SENASICA to perform a traceback audit to explain under which certification scheme it was produced and how it came to Mexico.

SENASICA response

  • SENASICA is available to perform a traceability audit on the CFIA product of interest to identify the certification scheme and its entry into Mexico.

CFIA finding

The CFIA could observe 3 inspections in 3 different operations. These products are coming to Canada directly or indirectly. The CFIA peer review team felt we were observing USDA NOP certification with not much mention of the LPO. We understand these products are for export and must meet the importing country's requirements. The CFIA peer review team doesn't believe the operators in Mexico have explored the benefit of the MCOEA. Based on the discussion with the two CBs, the number of Mexican operators certified to LPO is much lower than NOP.

SENASICA response

  • SENASICA agrees with this observation and reiterates its interest and commitment to joining forces with the CFIA to disseminate the benefits of the CMOEA among Mexican CBs and operators so that Mexican operators can enter the Canadian market with LPO certification.
  • Currently, Mexican growers certified under the NOP regulations can enter Canada and other countries, as they have not applied for LPO certification.

CFIA finding

It is our understanding that SENASICA's shadow report is part of the inspection report. We are not clear if SENASICA prepares standalone reports for shadowing inspections. It seems like SENASICA shadow and inspection reports are not shared with the relevant accreditation body.

SENASICA response

  • The report resulting from the attestation activity (shadow inspection) is detailed in the Detailed Report. This document is delivered to the CB at the end of the inspection and attached to its file for follow-up by SENASICA.
  • SENASICA appreciates the CFIA's observation. As a result of the shadow inspection, it will share critical points of the certification processes with the ABs to join forces in monitoring the certification activities and performance of the CBs.

CFIA finding

The CB inspection checklists refer mainly to NOP and very rarely to LPO. SENASICA did not make any comments on this issue during the office inspections and the witness audits.

SENASICA response

  • SENASICA appreciates the comment and will ensure that the OC checklists are those validated by SENASICA during the approval process and that they are more specific for evaluating LPO, regardless of whether they are designed to simultaneously evaluate LPO and NOP regulations.

CFIA finding

The CFIA peer review team observed inconsistency in the input verification. As discussed with the CBs, LPO does not accept OMRI approval. However, when the CFIA peer review team was onsite with the CBs and both CFIA and SENASICA looked at inputs, all were OMRI approved. SENASICA did not make any comments on this issue.

SENASICA response

  • The CBs must ensure that the inputs used in organic production are on the National List of Permitted Substances and have a Sanitary Registration issued by COFEPRIS. The Sanitary Registration is equivalent to the EPA registration.
  • The OMRI registration is another characteristic of the input; it is not a determining criterion for its use in production certified under the Organic Production Regulations (LPO); therefore, SENASICA did not provide any comments.
  • The CBs have this information and are aware that they are responsible for determining the use of inputs prior to or during the inspection, as well as verifying compliance with the criteria established in the Guidelines Agreement and the National List, in accordance with Article 40 of the Regulations of the Organic Products Law, Articles 20, 31, 235, 241, 246, 267 sections II and III, and 277 of the Guidelines Agreement.

CFIA finding

Although both CBs provide a lot of calibration training to their inspectors, one topic that require further improvement is scheduling the timing and length of the inspection appropriately. Both the CFIA peer review team and the operations didn't know when the inspection would start and finish and what would be covered as a scope. The CBs should clearly communicate with their inspectors the certification schemes that they assess compliance with.

SENASICA response

  • The CFIA's comment is appreciated. Although the OCs and inspectors scheduled an inspection that would have allowed SENASICA and the CFIA to witness the surveillance inspection process, considering several stages of the production chain, the inspection time was extended and the entire process was not observed.
  • It is important to note that the inspector at each CB develops an inspection plan, which is notified to the operator. This inspection plan details the activities to be performed, the timing of each activity, and the scope of the inspection, which was not met due to the timeframe.

CFIA finding

As a result of inadequate planning of the inspection, the CFIA peer review team was not able to observe the input output balance and traceability for the berries inspection. This was also noted by SENASICA but not classified as a nonconformity.

SENASICA response

  • It was not classified as a non-conformity because SENASICA was able to observe and verify that the traceability and mass balance audit carried out by the inspector was indeed completed, although this occurred outside of the established schedule.
  • This was recorded in the inspection closing report.

CFIA finding

Generally, a nonconformity is a result of a missing procedure or inadequate training. The first thing that should be looked at is if an NC is addressed is a procedure put in place / training conducted to ensure this same type of issue does not occur again. We observed two instances where the inspectors failed to focus on this in NC follow ups. There is room for improvement regarding follow up on corrective action implementation.

SENASICA response

  • SENASICA issues non-compliances or non-conformities to the CBs based on compliance with the criteria established in Article 18 of the LPO, Article 18 of its RLPO, and the Call for Approval. CBs must submit their root cause analysis and corrective actions, such as procedural improvements or training, to resolve and maintain their approval.
  • Likewise, CBs issue non-compliances or non-compliances that certified operators must resolve to maintain their LPO certification.

CFIA finding

The CFIA peer review team didn't see any LPO labels or LPO logos used on Mexican organic products. Even the Driscoll label for the domestic product refers to USDA NOP and shows the NOP seal.

SENASICA response

  • Products marketed in Mexico, according to the LPO, must contain information that complies with Articles 201 and 204 of the Guidelines Agreement.
  • If the product is not marketed in Mexico, the label is not required to include the information required in Articles 201 and 204 of the Guidelines Agreement.
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