Welcome to the 2020 review of the Australian Certified Organic Standard (ACOS), due to be published in early 2021. Painstaking efforts have been made to conduct a full review of the Standard, the most comprehensive review since 2010. An industry and public comment phase seeks your input.

The Review is now closed. Thank you for your submissions.


The Purpose of the Review

As the organic industry develops, so too does the need for up-to-date Standards which deliver the highest level of consumer satisfaction, market access, practicality and clarity for certified operators.

Since de-merging from the certification body now known as ACO Certification Limited in 2018, Australian Organic Limited, as peak body for the organic industry in Australia, has taken various steps to adapt into a highly valuable industry body for a strong organic industry. One of the key pillars of a strong organic industry is third party certification, to well agreed and recognised standards. The National Standard for Organic and Bio-dynamic Produce 3.7 is Australia’s government standard, currently enforced by law for exports and expected to be enforced domestically in the near future. For this reason, it is critically important that our own Australian Certified Organic Standard (ACOS) is fully aligned with the National Standard (NS), whilst still providing the additional market access for operators that our government has not yet provided, alongside clear details on areas of production not yet well specified in the National Standard.


Alignment with National Standard

In 2018, a one-way side by side analysis was conducted comparing the ACOS with the NS. We started with the NS and checked each clause on the same topic in the ACOS, and where variation existed, these were corrected and included in the ACOS 2019 version.

During 2020, a reverse side by side analysis was conducted, which started with the ACOS text which was compared with the NS. Variances have been corrected in this draft.


Incorporation of Notifications

In 2019, Australian Organic Limited established a formal and transparent procedure for publishing of notices related to the ACOS. These Notifications arise from regulatory changes or clarifications, as well as from submissions from industry, or the public for published interpretation, or updates to the ACOS. These Notifications are published on our website, and include some formal updates to the Standard. All Notifications of updates to the ACOS have now been incorporated into the new ACOS 2021 draft.



Sections and clauses of the Standard have been thoroughly reviewed and simplified where possible. This includes re-wording, correction and the removal of some clauses where repetition occurs.


Minimisation of internal references

To facilitate easy future review and updates to the ACOS, the use of internal references has been minimised.


Removal of references to external certification schemes

The ACOS has thus far included some references to overseas certification schemes such as the USDA NOP, JAS, and Korea. Since such references were occasional, and due to the ongoing review of overseas schemes and equivalency agreements, these references have been removed.


Administrative and typographical and consistency updates

The vast majority of changes in the ACOS draft are very simple, for example; changing CO (certification office) to CB (certification body). Many others are simply correcting inconsistent nomenclature, or correcting typos.


What you need to know

While the vast majority of changes are not substantive and are unlikely to directly impact certified operations or operators, there are some changes which are substantial. We invite a thorough review by concerned operators or members of the public, and as such, wish to bring to your attention the following areas, which include what could be considered substantive changes, and as such warrant careful review.


Substantive changes


Livestock producers

While the intent of the feed supplement allowance and drought feeding allowances remain unchanged, the wording has been updated to clarify what is allowed, and the need for a formal derogation for non-organic feed supplementation has been added. This is a requirement of the National Standard, with which we intend to align.

In line with industry expectation and resulting from extensive work in the area of pain relief, analgesia has been added as allowed, however noting that such use is only allowed for pain relief associated with surgical procedures – not as a general health treatment. As a precaution, an additional withholding period has been added.


Poultry producers

60-day re-certification period for eggs has been removed. It is our understanding that this allowance is not used by industry and conflicts with the NS.

Given the recent Avian Influenza mandatory confinement measures in Victoria, an allowance for potential temporary confinement due to mandated measures has been added.


Biodynamic beef producers

The allowance for 6-month conversion of organic beef cattle to bio-dynamic beef cattle has been removed. It is our understanding that this clause is not used by industry, and conflicts with the NS.


Sheep producers

Mulesing has been prohibited. Despite this still being allowed by the NS, export market and consumer expectation has vastly moved in this direction, and as such we intend to do the same. It is our understanding that this technique is not used by industry.


Pet care product producers

In line with the exclusion of cosmetic products intended for use on domestic animals from the requirement for an Organic Goods Certificate in the new Export Control Rules to be implemented in March 2021, a chapter has been inserted to allow for such products to be certified to the ACOS. This new section is based on the previously included cosmetics chapter which was removed in 2019 as required by COSMOS, the international standard for organic and natural cosmetics, with which Australian Organic Limited continues to align.


Fair Trade producers

The Fair Trade section of the ACOS has not been taken up by industry, despite it being available for many years, and as such has been removed. Fair Trade certification is not an area of focus for Australian Organic Limited.


Allowed Inputs manufacturers

The Allowed Inputs section has been removed entirely, to better reflect that such inputs are not certified organic as such, but certified Allowed Inputs for organic production. Such products shall continue to be certified to the ACOS 2019, until a new document specific to Allowed Inputs is published – expected to occur later in 2021. The Allowed Inputs certification scheme will remain, as this is an important pillar of compliance. The ACOS will remain relevant to the Allowed Inputs scheme, however the administrative, audit and review process will be streamlined and made more fit-for-purpose during 2021.



The above list is non exhaustive and is intended to bring to your attention what we see as substantive changes. The changes listed in the Proposed Change Log file are indeed that – proposed – and now is your chance to provide input into how these changes may be included in the Australian Certified Organic Standard 2021. Please refer directly to the Log file for further details, and if you would like to comment, use the comment form below.

Please note, if you wish to make comment on sections of the ACOS that are not proposed for update and hence not listed in the Proposed Change spreadsheet, please submit your request on the standard Application to Alter the ACOS form available here.

The Review is now closed. Thank you for your submissions.

Virtual Information Sessions

Owen Gwilliam (AOL’s Chief Technical Officer) hosted virtual information sessions on behalf of AOL in December 2020 and January 2021 to provide the opportunity to discuss any proposed changes and feedback.

Information Sessions:

Thursday 17 December 2020 | 10am (AEST) | Watch Again Here

AOL members can re-watch these information sessions in the member portal.

Review Form and Proposed Change Log

View the proposed changes to the ACOS 2019 in the below Proposed Change Log.

The comment period has now closed. Thank you for your submissions.

Questions and Feedback:

Any questions or feedback regarding the ACOS 2019 Review process should be directed to Owen Gwilliam at the details below:

E: Owen Gwilliam