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Mr Hugo Jansen,
4641 SP Ossendrecht
May 31, 2006
Dear Mr Jansen,
Subject: Complaint against Organic Agriculture Certification Thailand (ACT)
Further to my letter to you of March 31, 2006 and after some investigation I want to update you on
the following points:
1. Who is NN certified by?
Before January 2006 (the time of your visit), NN was solely certified by Soil Association
Certification Ltd of the UK initially based on inspections performed by SACert themselves and
then later contracted inspections by ACT of Thailand. From January 2006, NN has been certified
by ACT. This explains your concern about the absence of NN on ACT operator lists. If you should
ask ACT now for an operator list, NN should appear. This issue is therefore dropped from the
investigation and I suggest that you may like to correct this error/misunderstanding on your web
However, the fact that ACT are now certifying NN brings the issue directly under our scope of
Lastly on this issue, in your letter of March 14th and on your web site you question the
transparency of the sub-contracted inspection system between SACert and ACT. On that same web
site you also point out the problems with maps, language, culture etc. The latter in effect answers
the former doubt and is why the IFOAM Norms and organic legislation world-wide permit such
arrangements i.e. to use local knowledge, expertise, cultural understanding, language ability and
proximity to provide a rigorous inspection system. As you yourself found in Thailand, a foreigner
trying to find out what is really happening makes no sense.
2. Use of treated seeds
If indeed treated seed was used (and I have no further evidence as yet for or against this allegation)
I would like to point out that this may have been legitimate use under IFOAM Norm 4.1.2 which
‘Where untreated conventional seeds and plant materials are not available, chemically treated
seed and plant material may be used. The certification body shall establish time limits and
conditions for exemptions that permit use of any chemically treated seeds and plant materials’
Similarly under ACT standards clause 2.2.2:
‘In case seed and plant propagation cannot be from organic agriculture, using of conventional
seed is allowed but chemical treatment is prohibited. Exception can be made when organic
farming is in the early stage of development or there is unexpected accident; therefore, chemical
traded seed and plant propagation may be used. But by the year 2010, producers shall develop
seed production and plant propagation within the farm or exchange them with other organic
This aspect of the investigation however continues alongside your concern (though without
evidence) over the ability to produce sweet corn in Thailand organically and the implied use of
3. Manner of investigation
In your letter of March 14th you also suggest that you would like to see this case investigated
without notification of ACT. As I pointed out in my last letter, you yourself have done more than
anyone to ensure that any ‘cover up’, should one have been necessary, will have taken place. By
suggesting such a course, you are implying that ACT is complicit with the ‘fraud’ of using treated
seeds but without providing any evidence or even suspicion. We therefore are asking ACT to
conduct their own investigation into this case (which is our normal course of action) and to provide
a report to the IOAS. This we will do whether you wish to proceed in this manner or not.
4. Role of Vitoon Panyakul
You have not responded to me as to whether you wish to follow this up. To the ‘cynical’, as you
put it, the multiple role of Mr Panyakul may seem dubious. However as Board member of ACT he
will have no role in decision making in Thailand (this role is performed by a separate Certification
Committee) and at the the level of the IOAS, he has no role in decision-making with regard to
ACT. Recognising that the organic movement is at times small, both the IFOAM Norms and IOAS
procedures are absolutely rigorous in this regard and more so than more general requirements (e.g.
ISO65) set by industry in general. This issue is now considered closed.
In summary I am continuing to investigate the specific allegations on use of treated seed and the
implied use of conventional inputs.
I will contact you when I have further information.
David Crucefix PhD
Assistant Executive Director