Canadian Food Inspection Agency peer review report on Japan's organic system – 2023

On this page

• Abbreviations and special terms used in this report
• Executive summary
• 1. Background
• 2. Objectives of the assessment
• 3. Assessment criteria
• 4. Assessment protocol
• 5. Overview of the Japanese organic sector
• 6. Implementation of the Japan organic system
• 7. Japan import controls for organic products
• 8. Closing meeting
• 9. Overall conclusions
• 10. Findings
• 11. Next steps
• Annex A: Summary of the Canadian Food Inspection Agency (CFIA) Findings from the Assessment of Japan's Organic System (2023)

Abbreviations and special terms used in this report

CA

Competent Authority

CB

Certification Body

CFIA

Canadian Food Inspection Agency

CJOEA

Canada-Japan Organic Equivalency Arrangement

COR

Canada Organic Regime

DEFRA

UK Department for Environment, Food, & Rural affairs

FAMIC

Food and Agricultural Materials Inspection Center

ISO

International Standards Organization

JAS

Japanese Agricultural Standards

JOIC

Japanese Organic Inspectors Association

MAFF

Ministry of Agriculture, Forestry, and Fisheries

NC

Non-Conformity/ Noncompliance

Executive summary

This report summarizes findings made during the on-site joint peer review the Canadian Food Inspection Agency (CFIA) and the UK Department for Environment, Food & Rural Affairs (DEFRA) conducted on Japan Organic Program in August 2023.

This is the second joint peer review of a third country's organic system undertaken by the CFIA.

The objective of the peer review was to determine the extent to which the Japanese competent authority demonstrates conformity with the requirements specified in the Canada-Japan Organic Equivalency Arrangement (CJOEA).

The peer review was conducted from August 21-31, 2023. It included meetings with Japan's Ministry of Agriculture, Forestry and Fisheries (MAFF), Food and Agricultural Materials Inspection Center (FAMIC), two (2) certification bodies (CBs) and six (6) organic operators. The key elements of the peer review included the following:

1) Authorities

• Current organic legislative authorities, including regulations, standards, codes of practice, and arrangements. In particular:
  • authority to recognize and certify parties involved in Japan's organic system
  • authority to carry out monitoring and surveillance activities
  • authority to respond to non-compliances where risk has been identified, e.g. recalls, other control and enforcement activities

2) Government organization and resources

• The roles and responsibilities of the various government departments involved in the implementation of Japan's organic system
• The resources, responsibilities, functions, and coordination between the parties involved in Japan's organic system
• Competencies of the parties involved in the delivery of Japan's organic system

3) Enforcement and surveillance activities

• The role of MAFF, FAMIC and the CBs in inspection, surveillance, and enforcement of the organic regulations

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

This system guarantees that agricultural organic products certified under Japan's Organic Regulations can be exported and marketed in Canada as meeting the terms of the CJOEA.

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

1. Background

Canada and Japan started working towards establishing an equivalency arrangement to facilitate organic trade between the two countries in 2007. The initial and most recent onsite assessment of Japan by Canada took place in February 2014. On September 16, 2014, Canada and Japan entered into an arrangement recognizing the national organic systems as equivalent. The arrangement applied to plants, including fungi, and processed foods of plant origin, such as organic vegetables and tea.

On July 16, 2020, the scope of the recognition arrangement was extended to include livestock products (limited to the JAS organic specified scope of livestock) and processed food products containing livestock ingredients (limited to the JAS organic specified scope of livestock).

On August 31, 2023, the scope of the recognition arrangement was extended to include organic alcohol beverages.

As per the conditions of the arrangement, and following advance notice from the CFIA, Japan agreed to accommodate the CFIA's request to conduct an evaluation (on-site peer review) to verify how MAFF is carrying out the requirements of the Japanese organic system.

The CFIA peer review team was joined by UK's DEFRA organic team representative to form a joint peer review team. A joint peer review team enhances efficient use of resources for the maintenance of the equivalency arrangement with Japan and reduces multiple assessment activities.

2. Objectives of the assessment

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

3. Assessment criteria

The following references (regulatory requirements/standards) were considered during the on-site peer review:

• Terms of the CJOEA
• CFIA peer review procedure related to the Canada Organic Regime (COR)
• Japan Agricultural Standards (JAS)
  • JAS for Organic Products of Plant Origin
  • JAS for Organic Processed Foods (including organic alcohol beverages)
  • JAS for Organic Feed
  • JAS for Organic Livestock Products
  • JAS for Organic algae
• ISO/IEC 17011:2017
• ISO/IEC 17065:2012

4. Assessment protocol

The joint peer review team planned and conducted the on-site peer review in a manner which allowed the team to obtain sufficient information to confirm the observations and conclusions described thereafter. The on-site joint peer review was conducted in accordance with CFIA peer review procedure related to the Canada Organic Regime (COR) as well as the Concept paper on joint peer reviews developed by the Organic Equivalency Arrangements Working Group in 2020 and included visits to the following organisations:

As part of the on-site peer review, the joint peer review team reviewed each level of the Japan Organic System (administration, supervision, certification and production) to confirm that the responsible authorities have the necessary controls in place to ensure compliance with JAS Organic. In doing so, the joint peer review team:

• met with representatives from the MAFF Organic Team to review the administration of the JAS organic system and to discuss the roles and responsibilities in overseeing the system and the activities of FAMIC and the CBs
• met with representatives from FAMIC responsible for the accreditation of the CBs in Japan
• met with representatives from two CBs to discuss their certification processes and procedures
• witnessed four inspections (multi-day and multi-site) conducted by CB inspectors and witnessed by FAMIC auditors at organic farms and organic production operations to confirm their knowledge of the JAS organic system and competence to conduct inspections
• Visited an organic green tea farm and associated matcha processing facility and a soy sauce processor to observe the process and further understand the implementation of the organic requirements under the JAS organic system

5. Overview of the Japanese organic sector

Organic farming and production has been regulated in Japan since 1999 under the JAS Standards for organic plants and organic processed foods of plant origin.

As per the JAS annual report for 2022, there were 4915 producers and processors registered with the organic CBs in Japan in 2021 (from April 1 2021 to March 31 2022). The operator breakdown is as follows: 3081 organic plant products, 59 organic livestock products and 1775 organic processed foods.

As of April 1, 2022, Japan had a total area of 16 078 hectares of land farmed organically in 2021. In 2021, the three main crop types grown organically are vegetables, rice and green tea leaves. In 2021, the three main organic processed foods were soya milk, tea beverages and soybean curd. In 2021, the three main organic livestock products were raw milk, egg and beef.

According to the JAS annual report for 2022, the top three organic products exported to Canada are green tea products (60 521 kg), soybean paste (miso) (6939 kg), and soy sauce (1180 kg).

5.1 JAS organic legislation and standards

JAS organic standards are as follows:

• JAS for Organic Products of Plant Origin
• JAS for Organic Processed Foods (including organic alcohol beverages)
• JAS for Organic Feed
• JAS for Organic Livestock Products
• JAS for Organic algae

Additional technical criteria can be found on the JAS webpage.

6. Implementation of the Japan organic system

6.1 MAFF organic team

The Ministry of Agriculture, Forestry and Fisheries (MAFF) is a cabinet level ministry in the government of Japan responsible for oversight of the agriculture, forestry and fishing industries. MAFF is responsible for establishing food and environmental policies, including Japan's Organic System.

MAFF organic team is under the Standards and Conformity Assessment Policy Office and is comprised of 3 employees who are involved in the day to day administration of the organic JAS system. They all come from FAMIC and have a good understanding of JAS. One limitation faced by the MAFF organic team is that the employees are rotated every 2-3 years.

As Japan's Competent Authority, MAFF operates an approval system for Japanese CBs involved in the following scope of activities:

• production of organic products of plant origin
• production of organic processed food including organic alcohol beverages
• production of organic livestock products
• production of organic algae

As part of the peer review the joint peer review team focused on MAFF's role in regards to accreditation the CBs as well as the surveillance activities conducted by FAMIC, import controls, and controls on labelling and marketing of organic products.

6.2 FAMIC role under the JAS organic system

The JAS system is a third-party certification system. MAFF is the scheme owner of JAS responsible for the accreditation of the CBs. The technical assessment is conducted by FAMIC and includes on-site audits conducted in accordance to ISO/IEC 17011.

Under ISO 17011 accreditation bodies assess the competence of the Certification Bodies (CBs). This facilitates trade by promoting global acceptance of conformity assessment results issued by accredited CBs. This is strengthened if the accreditation bodies are peer- evaluated or externally assessed. As a signatory to the International Accreditation Forum (IAF), FAMIC is peer evaluated against ISO/IEC 17011, and other relevant standards and related criteria. It was confirmed that the last IAF peer review on FAMIC was conducted in 2022. FAMIC organic program was not directly reviewed as part of this review.

The supervision and accreditation assessments conducted in Japan are completed by FAMIC under a directive issued by MAFF to the President of FAMIC every year. In addition to its involvement in the surveillance of the accredited CBs, FAMIC's mission is to ensure the quality and the safety of fertilizers, soil improvement materials, agricultural chemicals, animal feed and feed additives, agricultural, forestry and fishery products. FAMIC bases its activities on eight Japanese laws including JAS.

FAMIC conducts market surveillance of organic products at retail level by verifying products bearing the JAS logo (label verification). The number of samples is approximately 5% of domestic producers.

FAMIC performs analysis for pesticide residues on the sampled products. There is no threshold for pesticide residues specified in organic JAS, however if the results are high or prohibited substances are detected, FAMIC contacts the operator directly and notifies the CB responsible for the certification. The CB must investigate the source of the contamination.

There are 623 employees working for FAMIC. They are located at Headquarters and in five regional centres. FAMIC has access to a sufficient number of competent personnel to deliver the assessment activities under the JAS accreditation scheme including 52 auditors, 14 assistant auditors, 9 trainees and 29 analysts of residues.

The competence, monitoring, and the training of the FAMIC auditors for the organic program were discussed. FAMIC has established a process for initial evaluation and on-going monitoring and training of its personnel. The training is done internally and includes practical exercise. The auditors have to pass an assessment before they are qualified to conduct audits. Training records are maintained and were accessible for review. The monitoring of the FAMIC auditors is based on the audit reports reviews.

The joint peer review team confirmed that FAMIC has implemented an internal audit and management review procedures specific for the JAS organic program. FAMIC shared the results from the 2022 internal audit and the management review with the peer review team and discussed the outcomes.

6.3 Approval and supervision of the Japanese CBs

Currently there are 51 accredited CBs in Japan from which 21 offer certification services outside Japan. CB accreditation by MAFF is valid for four years.

MAFF and FAMIC verify whether the CBs have undertaken their certification activities in compliance with the relevant rules and regulations, including JAS legislation, ISO/IEC 17065 and the business rules of the CB.

It was confirmed that FAMIC assesses the certification activities implemented by the CBs through annual audits which include at least one on-site office audit, witness audits, validation audits, residue testing of organic products and label reviews. FAMIC conducts the on-site office audits at least once every two years.

Every year FAMIC develops an assessment plan based on the number of the CBs in each region. It was discussed that usually the CBs are subject to one witness audit per year. However, those with a high number of operators can be subject to more witness audits. The validation audits are part of the office audit and focus on the inspection reports drafted by the CBs.

It was discussed that there is no requirement under JAS to rotate the auditors every three years. In general, if there are non-conformities (NC) identified at the audit, the same auditor will be involved in the follow up activities. The joint peer review team discussed at length the process of issuing and addressing the NCs under the JAS organic program.

It was confirmed that FAMIC HQ issues the NCs using pre-established criteria. The CBs are given 30 calendar days to respond. The decision to suspend, cancel and/or reduce scope of accreditation is made by MAFF. The suspension period varies depending on the situation and can be from 30 to 120 days. It is not lifted automatically. FAMIC is required to conduct a follow up assessment before an accreditation decision is made. The appeal process is outside of the JAS organic act. It is an administrative procedure that does not involve FAMIC. It was verified that there have not been appeals since organic JAS system came into force.

It was confirmed that MAFF accredits the CBs based on review of FAMIC's assessment reports.

The joint peer review team noted that MAFF does not accompany the FAMIC audit teams during any of the CB audits.

6.4 MAFF communication with FAMIC and the CBs

As part of the discussion with MAFF it was confirmed that there is on-going communication and exchange of information with FAMIC regarding the outcomes from the CB audits. However, there are no set meetings.

The joint peer review team was informed that MAFF and FAMIC hold an annual meeting with all CBs to address any emerging issues and share information about the surveillance activities conducted by MAFF/FAMIC. MAFF continues to improve communication tools such as its website, disseminating guidance in a standardized method by publishing site inspection handbooks, questions and answers on organic JAS, specific procedures for assessing compliance of substances.

6.5 Enforcement of the JAS organic requirements

The joint peer review team noted that under JAS unannounced inspections take place as a follow up to complaints or in accordance with Article 48-(1) –(ii)-(c)(d) of the "(amended) Regulation for Enforcement of the Act on JAS. However, the minimum number of unannounced inspection is not specified.

The CBs issue very few NCs to operators.

It was discussed that suspensions and cancellations of CBs and operators are exceedingly rare under JAS.

6.5.1 List of active operators

MAFF makes the list of operators publicly available. Operators details are available by searching the: Inspection and certification system for organic foods: Ministry of Agriculture, Forestry and Fisheries (maff.go.jp).

It is the responsibility of each CB to maintain their list of operators up to date and provide the information to MAFF.

6.5.2 Certification and supervision of operators

The joint peer review team visited the headquarters of two CBs. Both CBs have a well-developed quality system and related certification procedures. The CBs use an electronic database to save and track all certification related activities and information.

The CBs have been accredited by MAFF for compliance with ISO 17065 for several years and are subject to on-going surveillance. It was confirmed that both CBs were subject to various surveillance activities (office and witness audits) in 2022 and 2023.

The joint peer review team verified that each CB sends two sets of reports to MAFF: new certifications, cancellations and withdrawal (every time this occurs) and annual reports with an up-to-date list of all operators and the date of the last inspection.

The joint peer review team confirmed that both CBs have competent staff who deliver the certification activities in a consistent manner. The qualification of the inspectors is assessed based on MAFF's guidelines. In accordance with clause 6.1.2 of ISO 17065, both CBs have implemented procedures to ensure that on-site inspections are conducted by trained inspectors. Most of the inspectors attend the trainings organized by the Japan Organic Inspectors Association. In addition, each CB delivers annual training on their specific procedures.

The CBs monitor and evaluate the performance of the staff and the assessors annually. The inspectors are evaluated based on pre-established criteria such as number of inspections and the quality of the inspection reports. It was confirmed that the CBs do not witness on-site the work of the inspectors.

Both CBs have established certification systems which allow them to schedule the operators' inspections in a timely manner while ensuring a good rotation of inspectors (every three years).

The duration of each inspection varies depending on the nature and complexity of the operation. During each inspection, inspectors are required to verify the inputs used by operators. Under JAS Organic program, MAFF publishes a list of approved materials that is referenced by the CBs. For new inputs the operators are required to submit them to the CB for review. It was confirmed that as part of the inspections the inspectors conduct traceability and mass balance exercise. The inspectors do not take any samples since it is not a requirement under JAS. The annual inspections are scheduled and conducted approximately two months before the previous inspection. The inspectors are expected to submit their reports to the CB in two weeks.

As a result of the inspections, the CB inspectors may issue findings to the operator.

The peer review team noted that there is no consistent approach amongst the CBs when it comes to categorizing the NCs and the time frame for addressing them is left to the discretion of each CBs.

The joint peer review team discussed with the CBs their role in verifying imported ingredients in multi-ingredient products. Since under JAS all the imports of organic products have to be certified, the JAS label on the product is sufficient evidence that the product is organic. It is a responsibility of the importer to maintain a copy of the import certificates.

It was verified that both CBs are aware of the equivalency arrangements with Canada and the UK. Samples of completed exports certificates were reviewed and found compliant.

The joint peer review team confirmed that both CBs are subject to regular assessments by FAMIC. It was noted that generally if there are no NCs at the office audit FAMIC does not leave a report with the CB.

6.5.3 Organic operators inspections

The joint peer review team visited the following operations:

• Organic farm (rice) (witness audit)
• Organic processing facility (sake) (witness audit)
• Organic processing facility (soy sauce)
• Organic farm (tea) and processing facility (matcha tea)
• Organic processing facility (slaughter) (witness audit)
• Organic farm (livestock) (witness audit)

The joint peer review team witnessed 4 inspections conducted by 3 different inspectors employed by 2 different CBs.

The rice farm is fully organic and has been certified since 2005. The farm is certified for organic rice, and all harvest is for internal use for the sake processing facility.

Before conducting the inspections, the inspector prepared for the inspections using information provided by the CB. This included all information pertaining to the farm such as the organic system plan, past reports, organisational information of the operator etc.

It was confirmed that it was the 3rd time for this inspector to conduct the inspection at the farm. The inspector is a freelancer and conducts inspections for several CBs.

The inspection included an opening meeting, a tour of the rice fields, verification of the buffer zones, review of relevant records, inputs verification, traceability exercise, mass balance exercise and closing meeting. No samples were taken as part of the inspection. At the closing meeting both the inspector and the farm's representative signed an exit report and a copy was left with the farmer.

The inspection was witnessed by two FAMIC auditors. It is a regular practice for FAMIC to send two auditors for both the office and the witness audit.

The joint peer review team witnessed the closing meeting between the FAMIC auditors and the inspector. It is not noted how many times this inspector was witnessed by the FAMIC auditors.

FAMIC auditors commented on the degree to which the inspector followed the policies and procedures of the CB. They noted the thoroughness with which the inspector reviewed the records and her knowledge and understanding of the JAS standard.

The inspection at the sake processing facility was conducted by the same inspector and witnessed by the same FAMIC auditors. The inspection included an opening meeting, a full tour of the facility, verification of the production plan, review of relevant records, inputs verification, verification of the water testing results, mass balance on several products, label verification of selected products and closing meeting.

During the inspection at the sake processing facility it was confirmed that the company produces and packs both conventional and organic products. 10% of the production is organic products. The organic sake was introduced to the market in 2011. The organic sake is certified to JAS, EU and NOP. The inspector discussed how the company ensures that there is clear separation between organic and conventional products.

The JAS standard for organic alcohol has been revised since the last inspection and the inspector emphasised on the importance of updating some of the internal procedures. At the closing meeting both the inspector and the company's representative signed an exit report and a copy was left with the company. There was one NC issued related to the labelling and tracking of the products. Two weeks were given to the company to provide corrective plan.

The joint peer review team witnessed the closing meeting between the FAMIC auditors and the inspector. FAMIC auditors discussed several observations with the inspector however no NCs were issued.

The third inspection that was observed by the joint peer review team was at a cattle slaughter facility that is contracted out by 5 organic farms. Since the facility is included in the organic plan of each farm, it is visited 5 times a year by different inspectors. Each inspector has specific questions about the traceability of the animals from each farm. Both conventional and organic cattle are slaughtered at the facility.

The inspection was conducted by an inspector contracted out by a different CB. Before conducting the inspections, the inspector prepared for the inspections using information provided by the CB. This included information pertaining to the specific farm that contracts out the slaughtering facility.

It was confirmed that each inspection is on average no more than 2 hours. Usually the inspector does not leave a written report document with the facility, however if there are issues the inspector may come back for a follow up. The results from the inspection will be submitted to the CB.

This inspector has been observed several times in the past by FAMIC auditors. The joint peer review team witnessed the closing meeting between the FAMIC auditors and the inspector. FAMIC auditors discussed several observations with the inspector and asked technical questions however no NCs were issued.

The last inspection that was observed by the joint peer review team was at a livestock farm for Angus cattle. There are approximately 100 cattle that are free range and fed only by pasture and silage. Every month 2 cattle are sent to the slaughtering facility that was visited by the joint peer review team the previous day.

The inspection was conducted by an inspector contracted out by several different CBs. The inspection included an opening meeting, a full tour of the farm including all pastures, verification of the production plan, review of relevant records, inputs verification, and closing meeting. The inspector focused on the shipment/transportation records, application of the JAS logo, breeding records and medical treatments of the cattle. At the closing meeting both the inspector and the company's representative signed an exit report and a copy was left with the company. No issues were identified.

The joint peer review team witnessed the closing meeting between the FAMIC auditors and the inspector. FAMIC auditors discussed some technical questions with the inspector however no NCs were issued. It was confirmed that this inspector was observed in the past by FAMIC auditors.

The joint peer review team noted several points:

• in general, the CB inspectors do not explain the reporting procedure and the time frame for addressing any findings
• FAMIC auditors do not use any questionnaires/template for recording the observations from their witness audits
• FAMIC auditors only verbally inform the inspector of their observations
• FAMIC HQ provides only a high level summary to the CB of their surveillance once a year

The visits to the soya sauce processing facility and the green tea farm and processing facility allowed the joint peer review team to better understand how the operations meet the requirements of the JAS organic standard as well their interaction with the CBs, FAMIC and MAFF.

6.6 Management of consumers' complaints

Under the JAS organic system both MAFF and FAMIC can follow up on complaints.

FAMIC is responsible for managing complaints against the CBs. In the past few years no complaints have been received and, accordingly, MAFF has not needed to develop a system for tracking complaints.

Depending on the nature of the complaint the CBs can be involved as well if the complaint is against one of their operators.

7. Japan import controls for organic products

The JAS import system is governed by JAS organic. As per the regulations importers in Japan have to be certified if they import organic certified products under an organic equivalency arrangements.

Currently there are two ways for importing organic products into Japan:

• equivalent third countries
• Japanese CBs certifying in foreign countries

All organic products imported under equivalency arrangement must be accompanied by an export certificate including the relevant information from Article 35 of the Enforcement Regulations of the Act on Japanese Agricultural Standard.

8. Closing meeting

A closing meeting was held on August 31, 2023 with MAFF and FAMIC officials. Colleagues from the Canadian and the UK Embassies attended as well.

During the meeting, the joint peer review team presented a summary of the findings. MAFF and FAMIC officials had the opportunity to discuss these findings. Next steps were discussed and agreed upon.

9. Overall conclusions

• All parties involved in the assessment from the staff at MAFF, FAMIC, the CBs to the operators, were helpful, responsive, and accommodating to the assessment team during the visit
• There is commitment and good understanding from all parties involved in the implementation of the Japanese Organic Regulations
• MAFF staff is experienced in conducting organic inspections and committed to further develop the existing organic system. CFIA would like to continue working with the same staff at MAFF for a longer period of time before they are rotated to another department. This would permit for a deeper expertise to develop which would allow a better understanding and working relationship between our two systems
• FAMIC follows an accreditation process based on ISO17011 which covers compliance verification activities including CB headquarters, witness audits and validation audits
• FAMIC headquarter staff has good collaboration with MAFF and MAFF accredits the CBs based on FAMIC reports
• The visited CB is aware of the Canada and UK Organic Equivalency Arrangements with Japan, the export certificate, COI and the labelling requirements for organic products going to Canada and the UK
• The CBs have good management systems based on ISO 17065 and excellent record management
• The CB Inspectors observed by the joint peer review team conducted the inspections following the procedures established by their CBs
• The operators are committed to following and applying the organic production requirements. They were transparent and open about their production system during the peer review

10. Findings

MAFF is invited to provide a response on the joint peer review team findings listed below:

1. MAFF does not carry out consistent oversight activities of the regulated parties. The work of FAMIC is assessed mainly by reviewing their reports on the CBs. MAFF did not develop and implement a written procedure and methods for witnessing or assessing FAMIC's work or the work of the CBs.
2. ISO 17011 section 7.6.6 b) "requires the accreditation body to provide a written report on the outcome of the assessment to the conformity assessment body aka CB without undue delay and within a defined timeframe. This assessment report shall contain comments on competence as determined through conformity, the scope assessed and shall identify nonconformities, if any, to be resolved in order to conform to all of the requirements for accreditation. Comments on competence as determined through conformity included in the assessment report shall be adequate to support the conclusions arising from the assessment. The team's observations on areas for possible improvement may also be presented to the conformity assessment body but shall not recommend specific solutions." It was observed that neither FAMIC nor MAFF provide such a report to the CBs nor is the time frame for providing the report specified.
3. The CBs do not take a consistent approach when it comes to categorizing NCs and the time frame for addressing them. It is left to the discretion of the CBs. ISO 17065 section 8.7.4 requires the CBs to develop their procedures however it is the responsibility of the AB and the CA to ensure that all accredited CBs apply a consistent approach.
4. It was observed that under Japan's organic system there is no requirement for the CBs to collect samples when there is a reason to suspect the organic product has come into contact with a prohibited substance.
5. It was observed that under Japan's organic system there is no requirement for the CBs to conduct unannounced inspections. The only time when an additional inspection can be conducted is as a complaint follow up.
6. JAS organic standard does not have specific prescriptive requirements regarding distance for buffering the organic crop from potential contaminants which might lead to variations in the interpretation of the certification requirements by different CBs.

11. Next steps

MAFF is invited to provide response to the findings within 30 working days of receipt of the draft report. These are included in Annex A.

The final report will be posted on the CFIA external website as per the terms of the CJOEA.

Annex A: Summary of the Canadian Food Inspection Agency (CFIA) Findings from the Assessment of Japan's Organic System (2023)