www.demeter.net

International Certification Office (ICO)ICO Quality Management Manual –Public Summary
Public Information Document
Contents

2022-07-08

1

What is the ICO? ........................................................................................................... 22

To which standard does the ICO certify? ....................................................................... 2

3

Co-operation with organic certification bodies ................................................................ 2

4

Conversion to Demeter .................................................................................................. 3

5

The Role of the Advisor ................................................................................................. 3
5.1

General ................................................................................................................... 3

5.2

Advisory During Conversion .................................................................................... 3

5.3

Relationship and Communication with Advisors ...................................................... 4

5.4

Advisor’s Presence at Inspection............................................................................. 4

6

The Application and Certification Process...................................................................... 4

7

The annual certificate renewal process .......................................................................... 5

8

Announced and unannounced inspections .................................................................... 6

9

Non-conformities and corrective actions ........................................................................ 810

Sampling and testing ..................................................................................................... 9

11

Appeals and complaints ................................................................................................. 912

Impartiality and Non-Discrimination ............................................................................... 913

Competence management............................................................................................11

14

Responsibility ...............................................................................................................11

15

Glossary of terms .........................................................................................................11

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1 What is the ICO?
The International Certification Office (ICO) of the Biodynamic Federation Demeter International(Federation) was established for the purpose of certifying operators and products in countries
that do not have their own Demeter certifying organisation (Figure 1).

Figure 1: The ICO’s role in theFederation

The ICO is committed to supporting
the integrity of the trademark and development of biodynamic agriculture
through the delivery of its certification
programme.

2 To which standard does the ICO certify?
Figure 2: The Demeter standard in relation to general organic production rules. “ICO
Annex” refers to those sections of the Demeter standard, which leave the definition
and interpretation to each certification organisation.

The ICO certifies to the Demeter Standard (https://www.demeter.net/certification/standard/). This is a standard that requires compliance with organic standards (Regulation (EU) 2018/848 in Europe, NOP in the USA, etc.), but in many
aspects goes far beyond the general organic requirements. The ICO requires
a valid organic certificate for Demeter operators.
Wherever there is a risk of non-compliance with basic organic rules, ICO has
the right and duty to also verify compliance and to issue sanctions related to
non-compliance with these rules, where applicable. The ICO may decide differently on these issues than the organic IB.
In several sections, the Demeter standard reads, e.g., “this must be decided
by each certification body”. For these parts, the ICO Annex applies (Figure 2, blue box). This
Annex will be published on the Demeter website.

3 Co-operation with Organic Inspection Bodies
In most cases, the ICO works together with organic inspection bodies (IBs). The ICO chooses
the IBs it trusts. Inspectors must be approved by the ICO. When organic CBs conduct

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inspections, they normally combine the organic and the Demeter inspection in one. In somecases, the ICO has its own inspectors.
The organic IBs submit their inspection reports (for organic and Demeter) and organic certification decision to the ICO, which then makes the Demeter certification decision.

4 Conversion to Demeter
Farmers starting conversion must submit a written conversion plan. According to the ICO Annex, farms with more than 5 ha cash crops must have the support of a recognised Demeter
advisor for this purpose (see https://www.biodynamic-advisors.org/). The conversion plan mustbe signed by the responsible farm manager and the Demeter advisor.
The conversion period starts with the approval of the conversion plan, which is also the dateof signing the license agreement. The normal conversion time for a farm to achieve Demeter
certification is three years. The whole farm must convert to Demeter, including all fields, crops,
and animals, and must comply with the standard from the beginning of conversion. The only
exception to this general rule: when the approved conversion plan specifies certain development steps for a later date. One of the most basic requirements is application of the biodynamic
preparations on all productive areas belonging to the farm.
If the farm has been certified organic before, the conversion period may be reduced. For further
details, refer to https://www.demeter.net/certification/standard/. If ICO finds that the farm is notready for certification, the conversion may be prolonged. If inspectors find critical non-conformities during conversion, the farm must start again from the beginning or comply with suspension
periods.

5 The Role of the Advisor
5.1

General

Advice and certification must be strictly separated. Advisors must not get involved in certification decisions, while inspectors and certifiers must not provide advice to licensees.
5.2

Advisory During Conversion

Good quality advice is especially important for those converting to biodynamic production andworking toward Demeter certification. Therefore, it is a requirement for farmers to have a recognised Demeter advisor during their conversion period. This requirement ends with the licensee’s first full Demeter certificate. It is recommended, however, to maintain a relationship withan advisor as long as the farm needs their advice.

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5.3 Relationship and Communication with Advisors
The task of the advisor is to provide
advice and support. Advisors cosign the conversion plan with the licensee, so it is clear that the conversion is a joint effort.
The ICO has a direct relationshipwith licensees. This has a legal basis in the license agreement that theFederation and the licensee sign,
but also a practical basis in that it is
the licensee who is certified. Therefore, all communication regarding
applications, certification, approvals, derogations, exemptions, corrective actions, appeals, termination of license agreement
etc. takes place directly between ICO and the licensee (Figure 3). Advisors should support
licensees to undertake this communication directly with the Federation. All parties should beworking with the aim in mind that the licensee will become independent of the advisor by theend of the conversion period.

Figure 3: Communication between ICO, Licensee and Demeter Advisor.

If the licensee signs a data releasedeclaration, the Demeter advisor
can be copied into communications.
5.4

Advisor’s Presence at Inspection

Inspections for Demeter certification look at the systems and practices of the licensee to see
whether these meet the requirements of the Demeter Standard. As it is the licensee who is
responsible for the daily work on the farm, it is also the licensee who must take responsibility
for inspections. The advisor can provide support in preparing for the inspection and can bepresent for the inspection itself, but should play a supporting role only. The inspector will address the licensee during inspection including the closing meeting when any issues are summarised. It is the licensee’s responsibility to clarify any issues raised during the certification
process. The inspector has the right to talk to the licensee in private.

6 The Application and Certification Process
Figure 4 describes the application process for new farms, from first contact to Demeter certification. For processors or traders, the process is simpler, because they do not need to undergo
conversion (Figure 5). The application process is put on hold if there are outstanding financial
issues.

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Figure 4: The application process for new farms. Please follow the arrows. Blue represents the applicant’s steps(who becomes a licensee, once he / she has signed a license agreement), green the steps by ICO, purple the inspection body.

Figure 5: Simplified application process for new processors, traders, or distributors.

7 The Annual Certificate Renewal Process
Once the process described in Section 6 has been completed and the first valid Demeter certificate has been obtained, then the certificate must be renewed every year. The process issimilar to Figure 5, but simpler, as shown in Figure 6.

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ICO puts the renewal process on hold when there are outstanding financial issues.

Figure 6: Simplified scheme for annual certificate renewal process

8 Announced and Unannounced Inspections
The “organic” inspection (verifying compliance with the EU Regulation on organic farming
and/or other government standards) may be combined with the Demeter inspection, or they
may be separate.
The ICO or the organic IB will inform the licensee of the date of inspection several weeks’before. This allows the licensee to prepare, including all documentation typically required by
the inspector (Table 1).
Table 1: Overview of records which Demeter operators should keep. For more details, refer to the Demeter standard.

Farm

Processor / Trader (as applicable – including on-farm processing)

•
•
•
•

•

•

•
•

•

•
•

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Farm map
ICO plot list
Floor plan for farm buildings
Conversion plan, evidence of implementation (during conversion time)
Inspection report, certificate with certified areas and crops from organic certifier
Evidence of correcting non-conformities
from organic certifier
Invoices for purchase of all farm inputs,
including seeds/seedlings and biodynamic preparations
Technical datasheets and evidence ofcompliance with the Demeter standard
for all farm inputs
Invoices for sale of all products
Bookkeeping

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•
•

•

•
•

•
•
•
•

List of all products requested for certification
Floor plan for all processing and storage facilities
Inspection report, certificate, and evidence of corrective actions from organic certifier
Invoices for purchase of all raw materials / ingredients / additives / processing
aids
Recipes
Technical datasheets and evidence ofcompliance with the Demeter standard
for all additives and processing aids
Invoices for sales of all products
Processing records
Storage records
Transport records

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Farm

Processor / Trader (as applicable – including on-farm processing)•••

Bookkeeping
Quality manual with detailed procedures•

LabelsFarm diary, including application records for fertilizers, crop protection products, biodynamic preparations
Larger or complex farms: quality manual with detailed procedures
Labels••Announced inspections normally follow a standardised procedure, as shown in Figure 7. Thismay change, because inspectors are encouraged to adapt their procedures to the specificsituation at each operation. Typical inspection time, depending on size and complexity of each
operation, varies between two hours and two days. In exceptional cases, it may take longer.

Figure 7: Standard procedure of an announced inspection.

In addition to the annual announced inspections, ICO conducts additional inspections, which
may be announced or unannounced. These are more focused on specific issues, e.g.:▪

Verifying implementation of corrective actions (see Section 9)▪

Verifying compliance with the Demeter standard during critical periods of the year
(e.g., typical time of fertilizer use, or crop protection, or harvest)▪

If the annual inspection to a processing facility takes place at a time when no Demeter products are being processed, an additional visit may be conducted when Demeter processing takes place▪

Complaints from insiders or third parties may lead to additional inspection visits.

ICO aims to conduct additional inspections with approximately 10% of licensees per year. “Unannounced” really means “unannounced”. The licensee should not expect to be notified one
or two days before, as in some other certification programmes. Based on the license agreement, during such unannounced inspections the inspector must be given access to all fields,
premises, and records. Figure 8 describes the simplified procedure for such inspections.

Figure 8: Simplified procedure for unannounced additional inspections. A formal opening meeting is not required.
Inspectors are instructed to be flexible; therefore, e.g., they may sometimes review documents before the physicalinspection. The report for such an inspection is typically much shorter.

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The operator must actively supply all information that is relevant for the inspection, both during
announced and un-announced inspection. Operators must allow inspectors to speak to any
staff they consider appropriate. The ICO asks inspectors to conduct such interviews preferably
in the absence of management. Per the contract, sampling must be allowed, as well as taking
pictures, or collecting any other kind of evidence the inspector considers necessary during
unannounced inspections. Inspectors must be given access even if the manager is absent ordoes not have time. In most operations, a deputy should be available, if the manager is not.
Refusal to co-operate with inspectors, may lead to cancellation of the license agreement.
In special situations, when there is a high risk for the inspector (pandemic, violence, etc.), theICO may decide to allow onsite inspections to be replaced by online inspections.
Starting from January 2023, the cost for additional risk-based inspections, sampling
and testing will be invoiced to the licensee.

9 Non-Conformities and Corrective Actions
Inspections (announced or unannounced) can have different outcomes:(a) the operator is fully compliant(b) there are non-conformities, but these are correctable(c) there are critical non-conformities, which cannot be corrected (at least not in the shortterm).
Figure 9 provides an overview on how the ICO manages these different cases. If major nonconformities are repeated, or not corrected within the agreed timeline, this may lead to suspension or withdrawal of certification.

Figure 9: Possible outcome of inspections and different ways to follow up on non-conformities found during theinspection, depending on the type of non-conformity (=NC).

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10 Sampling and Testing
Based on a risk analysis, ICO takes samples from certain licensees. Inspectors may take samples from crops on the field, from soil, from harvested, stored, or processed products, fromfarm inputs, or whatever may be appropriate for verifying compliance with the Demeter standard. Inspectors are trained for following standardised sampling procedures, ensuring the integrity (chain of custody) of the sample, and avoiding cross contamination during sampling, storage, or transport of the sample.
Samples are sent to accredited laboratories, accepted by ICO. The licensee receives a copyof the laboratory test report.
If test results raise suspicion that substances or methods may have been used which are notallowed under the Demeter standard, the licensee has the opportunity to comment on the result
before the ICC decides. Only when the result is clear (e.g., a test shows a Demeter farm has
used synthetic pesticides), a suspension or withdrawal of certificate may be issued without theopportunity to comment. This does not affect the right to present an appeal (Section 11).

11 Appeals and Complaints
If the licensee feels that a certification decision is incorrect or unfair, he/she can file an appeal
within one month. The appeal should be backed by as much evidence as possible. The appeal
will be reviewed by a person that is different from the one who made the initial decision andthen a decision is made in the International Certification Committee (ICC, see Figure 1).
If the licensee is not happy with the result of this appeal process, a second level appeal canbe filed within two weeks. The Supervisory Board of the Federation will then appoint an appeals
committee, composed of experts as appropriate for each case. Prior to this, the appellant must
deposit 750 €, which the Federation will refund in case the committee finds the appeal to bejustified.
Appeal can be put on hold if there are outstanding financial issues.
Not only licensees, but also consumers may present complaints, workers on a Demeter farm,
neighbours, non-governmental organisations, or whoever believes that something is goingwrong, e.g., with an inspector, or in a Demeter operation. Complainants should preferably disclose their identity. If the complainant believes that confidentiality should be respected, thesource of information will not be disclosed. However, anonymous complaints will also be investigated, provided they are plausible and substantiated by evidence.

12 Impartiality and Non-Discrimination
The Federation recognises the need for, and importance of, impartiality in the process of certifying products and processes and is committed to safeguarding the impartiality and the integrity of its affairs.
The Demeter certification programme is accessible to all applicants who fall in the scope of thestandard, regardless of size or type of operation, provided they commit themselves to comply
with the International Demeter Biodynamic Standard. All applicants to and licensees of theschemes shall be treated on a non-discriminatory basis. In very rare cases, however, wherean applicant/licensee is considered to be a risk for the reputation and/or credibility of the2022-11-03

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international trademark community, the ICO may turn down an application or cancel a contract
without specifying the reasons.
How the ICO ensures impartiality:
The ICO is part of the Federation, andthe Executive Board (EB) of the Federation is responsible for the ICO’s quality
management. Neither the EB nor the Supervisory Board get involved in individual
certification decisions. Both the ICO andthe International Certification Committee(ICC) are completely autonomous in thisregard.

At least two different persons (the inspector and the certifier) participate ineach certification process. The inspector,
who collects the facts on the ground, is
not the one who makes the final certification decision. A second person looking atthings more distantly, helps to achieve
more objectivity.

The second person (certifier) forwards
complex cases to the ICC – a committee
composed of several experts with longterm experience.
There is a clear separation between any
commercial or consultancy activities on
the one hand, and inspection and certification on the other hand.
The ICO decides if a person involved in
production, processing, trade, or consultancy can conduct inspections or certification to other licensees, or to other industries only, or will lose his/her approval
as a whole. If a person is, e.g., involvedin Demeter wine making, he/she can be
an inspector on cereal or livestock farms,
but not in other wineries.

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Anybody involved in inspection or certification, must annually declare his/her
conflicts of interest.

The ICO takes seriously and investigatescomplaints from licensees, whistle-blowers or third parties, concerning lack of
impartiality or even corruption. If theyhold true, the involved person (or organisation) will lose the approval. If necessary, inspections conducted by that person will be repeated.

13 Competence management
The ICO is responsible for the competence of everybody for their respective tasks. This refers
especially to inspector and certifiers. Demeter inspectors must be trained and approved by the
ICO. Rigorous selection of staff, detailed work instructions, regular trainings and monitoring
during internal audits are essential for ensuring the necessary competence.

14 Responsibility
The overall responsibility for the Quality Management of the international Demeter certification
scheme lies with the Executive Board of the Federation.
Day-to-day responsibility for the implementation of quality management lies with the Head of
the ICO with the support of the ICC.
The Accreditation Council of the Federation regularly monitors the ICO, to ensure the organisation follows fair, transparent, and rigorous procedures, as outlined above.

15 Glossary of terms

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Additional Inspection

This is an inspection that takes place in addition to the annual regular inspection. Such additional inspections may be announced or unannounced.

AdvisorFarmers with more than 5 ha must work with a recognised Demeter advisor(= consultant; see https://www.biodynamic-advisors.org/en/directory-advisors ).

ApplicantA legal entity that is in the process of application. From the first contact until
signing a license agreement, the entity is considered an applicant.

Federation

Biodynamic Federation Demeter International. A federation of the biodynamic organisations in more than 40 countries, with its legal residence inDarmstadt, Germany.

Biodynamic

The agricultural practices as defined in the Demeter Standard

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Certificate

A Demeter certificate confirms compliance with the Demeter Standard andallows the licensee to use the Demeter trademark and claim Demeter quality of the products, within the terms defined in the license agreement.

Certification

The entire process from reviewing applications through making certification
decisions, is called “certification”

Certifier, certification officer

Any certification process involves, as a minimum, two persons (“four eyes
principle”). In the case of Demeter, the two persons are the inspector whocollects evidence on the ground and writes an inspection report, and thecertifier, who reviews the report, issues non-compliances, and makes a certification decision. Sometimes also called “reviewer”, “evaluator” or “evaluation officer”.

Contract = license agreement

Operators sign a license agreement with the Federation.

Conversion

Conversion is the period from a conventional or organic farm to a Demeter
farm. A farm can either go through organic and Demeter conversion at thesame time, or, if it is already certified organic, undergo an additional conversion from organic to Demeter. In either of these cases, minimum time fromsigning a contract with the Federation and selling products with reference to
Demeter, is 12 months.

Corrective
ActionWhen the ICO finds a major non-conformity during the certification process,the applicant or licensee must resolve it with a corrective action. The certifier assesses if the corrective action is appropriate and satisfying. In somecases, the corrective action consists of something that has already been
done at that point (e.g., submitting a picture showing that Demeter products
are now being stored in a separate shelf). In other cases, a detailed corrective action plan is expected, including timelines for the implementation ofeach step.

DemeterStandard

Refers to the entire International Demeter Biodynamic Standard, as published at https://www.demeter.net/certification/standard/

ExecutiveBoard

The operational management of the Federation

ICC

International Certification Committee. The ICC monitors and advises the
ICO. In complex cases, it is not the certifier who decides, but by the ICC.

ICOInternational Certification Office. The certification department of the Federation.

Inspection, in- Verification of compliance of an operation with the standard. In the Demeter
spectorcontext, the terms “inspection”, “audit” and “control” are used synonymously.

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LicenseeA licensee is a contract partner of the Federation, who has permission (license) to use the Demeter trademark for his/her products. Conditions forbeing an approved licensee are: (a) signing a license agreement, (b) having
a valid certificate, and (c) payment of the license fees.

Non-conformity: Minor

Any deviation from the Demeter standard and from requirements of the license agreement, which does not directly compromise the integrity of the
product, but needs correction.

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Non-conformity: Major

The integrity of the operation, product or batch has been directly compromised, but the integrity of the operation can be recovered. Examples:
•
•
•
•
•

Non-conformity: Critical

Accidental contamination with prohibited materials
Non-intentional commingling of Demeter with non-Demeter products
Excessive number of minor non-conformities
Use of conventional seeds or propagation material for sales crops
without exemption
Lack of biodiversity

A serious or repeated failure of the system in which the integrity of Demeterproducts is compromised, which leads to no certification of the licensee.
Examples:• Deliberate fraud• Intentional commingling of Demeter with non-Demeter products
•
•

•
•

Obstruction of the work of the inspector / refusal to allow samples to be
taken
Storage or use of prohibited materials (e. g. chemical fertilisers/pesticides)

Contamination of Demeter products through systems failure
Excessive uncorrected major non-conformities

Operation,
operator

Synonym to “unit” or “entity”, often used in the certification context. An ”operation” can be a farm, a processing unit, or a trader. Not necessarily identical to a “legal entity”, because one legal entity can own several operations.

Premises

Buildings and land belonging to an operation. By signing the contract, theapplicant or licensee agrees to give the inspector access to the premises at
any time, for announced or unannounced inspections.

Processing

Any post-harvest (after harvest) handling of agricultural produce. As opposed to EU food law, the term “processing” in our context is not restricted
to activities that significantly change the characteristics of the product (e.g.,
by converting flour to bread), but includes simple processes like cleaning,sorting, packaging, or labelling. However, transport and storage are not defined as processing. According to the Demeter standard, processing must
be done in a way that preserves or enhances the biodynamic quality offood.

Unannounced Additional inspection conducted without warning. “Unannounced” normally
Inspection
really means what the word says.

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