SOE: Mass Balance & Traceback

December 1, 2023

SOE: Mass Balance & Traceback

Leading up to the implementation of the Strengthening Organic Enforcement (SOE) Rule approaching on March 19, 2024: this article is in relation to the regulation change regarding: Mass Balance and Traceback.

What is a Mass Balance?
It is defined as a reconciliation of the volume of incoming raw material against the total amount used in the resulting finished products, taking into account process waste and rework. The purpose is to verify that the organic inputs purchased and used by the operation are sufficient in quantity to produce the organic products that were sold.

Each operation’s record system keeping is distinctive, however examples of documents that can be used to complete a mass balance include but are not limited to:

• Ingredients receiving records and purchase invoices

• Invoices of services rendered (for Operations that do not physically receive the product)

• Inventory records for raw and finished goods

• Harvest logs (Crop operations)

• Planting records (Crop Operations)

• Sales and shipping records for finished goods

• Material/Input records and purchase invoices/orders

Mass Balance FAQ:

How do you comply if you have not made any organic sales?
You must demonstrate the ability to meet this requirement, therefore the developed record keeping system documents will be reviewed. In addition, if your operation handles/ grows non-organic products, those volumes may be used to test the mass balance system in place.

What is a Traceback?
A trail of documentation that can be used to trace the origin of the product, including seeds, final product, and material inputs. The system should also show that it can trace forward and indicate which customer(s) received the product. This is usually accomplished by lot coding materials throughout a process and recording these lot codes at different points in the process.

NOTE: The mass balance and traceback exercises must be conducted onsite by the inspector and cannot be prepared in advance. The inspector will choose the timeframe, product and request specific documentation during the onsite inspection.

As a reminder, these exercises are currently required under Regulation 205.103 Recordkeeping; however, keep in mind that with the SOE regulation change, the requirement now falls under 205.400(g)(8) & 205.400(g)(8)(9). This regulation makes it mandatory for a mass balance and traceback exercise to be conducted at all inspections. This includes but is not limited to unannounced inspections, Supply Chain Audits, and annual onsite inspections.

Failure to Comply
Failure to comply with these requirements, will result in a Non-Compliance and possible further adverse actions.

Primus Auditing Ops Organic Trainings:

Be aware of Organic trainings being offered through our Training Center.

Our calender and Registration information can be found here.

Addtional Information

For Information on all SOE updates, click here.

If you have any questions regarding Strengthening Organic Enforcement, please do not hesitate to contact us at: QAOrganics@pao-usa.com or 805-623-5248.