Dear Mr Jansen,

Subject: Complaint against Organic Agriculture Certification Thailand (ACT)

I have now had time to look through the details of your complaint against ACT submitted by email on

March 14th which I acknowledged that same day. We also talked about your concerns previously during

the BioFach fair in Nuremberg, February 16-19, 2006.


Your complaint is based on two main points:


1. The allegation that the organic farm Bankao 2 of the company NN in Thailand,

which is certified by ACT has used and is using treated seed of sweet corn in their organic production

fields. You visited the fields several times in December 2005 and yourself found seedlings in situ with the

remnants of treated seed attached. In one of the fields you saw a tractor and seed drill containing treated

sweetcorn seed.

2. That the operator NN does not appear on the public listing of ACT as required by IFOAM Norms

requirement 5.2.1h.

In addition you raise a number of other concerns based on your interpretation of your observations and

discussions in Thailand as follows:

3. Concern that the operator NN is using non-permitted forms of nitrogen fertiliser perhaps in soluble


4. Concern that it is very difficult to grow organic sweetcorn in Thailand thereby implying that NN must be

using conventional methods to achieve their results;

5. Concern that the role of Mr Vitoon Panyakul as operator, ACT Board member and IOAS Board and

Accreditation Committee Member is reason to doubt the integrity of the organic guarantee system in



Ít is my task at this time to make an initial assessment of the validity of your complaint, which is essentially

a judgement of its relevance to the accreditation programme and therefore whether it is within the brief of

IOAS to investigate.


Points 1, 3 and 4 above which together raise doubts as to whether the operator NN is producing in line

with relevant organic standards is certainly relevant to our accreditation programme.

Point 2 may well be relevant but my initial research indicates that NN is not certified by ACT but by Soil

Association Certification Ltd of the UK. ACT is contracted by SACert to perform the inspection. This

would explain why NN is on the certified list of SACert and not ACT (according to our records as well

as any you have obtained). If this is the case, then the responsibility lies with SACert and your complaint

should primarily be to them, or to us about them. Having said that I note the use by NN of the ACT logo

in the presentation pdf that you provided to me which suggests at the very least that NN think they are

certified by ACT. I will investigate.

With regard to point 5, if you want to raise this as a formal complaint against the IOAS, please do so and

we will deal with that separately.

I will also add one further issue: according to your account, lack of response to a complaint by ACT to

your request concerning the operator list.


As per our procedures, I am attaching to this email our complaints procedure. It is our policy to maintain

confidentiality of the complainant, however we would like to point out that given your discussions with

many people (who are not limited by our confidentiality policy) during BioFach, it is quite possible that

ACT are well aware already of your complaint.

Although you suggest you have little faith in seeing results from a complaint process, I want to assure you,

as I did at BioFach, that we take such complaints very seriously and will pursue the issue to whatever

conclusion it leads. Previous complaints that we have investigated and found justified have resulted in

operator suspension and disciplinary actions and corrective actions and sanctions against the certification

body. You will have to make your own conclusions.

Thank you for submitting this information and your concerns about the integrity of organic products.


Yours sincerely,


David Crucefix PhD

Assistant Executive Director