In a certification-based supply chain, trust in certification bodies is critical. When a certification body loses its approval, certified companies, brands, and buyers often face uncertainty around certificate validity, transaction documentation, and continued use of certification claims. To address such situations, clear guidance exists on how certified entities should proceed when their certification body is terminated. This article explains the key takeaways, compliance steps, and practical implications for companies affected by the termination of a GOTS-approved certification body.
Why Certification Body Termination Matters
Certification bodies are responsible for:
Issuing Scope Certificates.
Issuing Transaction Certificates.
Approving labels and certification claims.
Verifying compliance through audits.
When a certification body’s approval is terminated, it immediately loses the authority to perform these functions. However, this does not automatically invalidate previously issued certificates or halt business operations. Understanding the correct next steps is essential to avoid compliance risks.
Validity of Existing Scope Certificates
A key reassurance for certified companies is that:
Scope Certificates already issued remain valid until their stated expiry date.
Certified entities remain visible as certified during this period.
Companies may continue using certification claims and logos in line with their valid Scope Certificate.
Termination of the certification body does not retroactively cancel valid certificates.
Mandatory Migration to a New Certification Body
All companies certified under a terminated certification body must migrate to a new approved certification body as soon as possible.
Key Migration Principles
Companies may choose any approved certification body.
Previously paid licence fees for the same year are not charged again.
Licence fees apply normally for future certification periods.
Migration follows a defined change-of-certifier process.
The new certification body conducts its own independent assessment.
Documentation such as audit reports, corrective actions, and compliance records must be transferred to the new certification body to support recertification.
What Happens to Transaction Certificates?
Transaction Certificates require special attention during migration.
Validity of Existing Transaction Certificates
All Transaction Certificates issued before termination remain valid unless withdrawn.
These certificates can continue to support trade and traceability.
Issuing New Transaction Certificates
The terminated certification body cannot issue new Transaction Certificates.
After migration, all new Transaction Certificates must be requested from the new certification body.
The new certification body issues certificates based on its own assessment and volume reconciliation.
This ensures continuity while protecting traceability integrity.
Selling Goods During the Migration Period
Certified companies are allowed to:
Continue producing certified goods.
Dispatch certified shipments during recertification.
Use the previous licence number on goods produced before receiving a new one.
This flexibility helps prevent supply chain disruptions while migration is underway.
Extended Timeline for Transaction Certificate Applications
Normally, Transaction Certificates must be applied for within a defined time window after shipment. For companies affected by certification body termination:
A one-time extended application window was allowed.
The extension applied to both:
Former clients of the terminated certification body.
Buyers are relying on incoming Transaction Certificates.
This accommodation recognised the administrative delays caused by unexpected certification changes.
Responsibilities of the New Certification Body
The new certification body:
Is fully responsible for all Transaction Certificates it issues.
May reject applications if sufficient evidence of certified status is not provided.
Must ensure proper volume reconciliation and traceability.
Retains the authority to make independent certification decisions.
Certification does not automatically transfer without evaluation.
Sale of Certified Goods With Labelling
Certified goods with correct labelling may continue to be sold in:
Business-to-business markets.
Consumer markets.
It is common for Transaction Certificates to be issued after shipment. However:
Buyers must continue due diligence.
Certification requirements remain fully applicable.
Delays do not justify reduced compliance expectations.
Status of Approved Inputs and Accessories
Inputs and accessories approved by the terminated certification body:
Remain valid until their stated validity date.
May require migration to another approved certification body at a later stage.
Continue to be subject to version-based transition rules.
Accessory and chemical approval continuity helps maintain production stability.
Common Mistakes to Avoid
❌ Assuming certificates are invalid immediately.
❌ Delaying migration to a new certification body.
❌ Applying for Transaction Certificates from a terminated body.
❌ Skipping volume reconciliation during migration.
❌ Using certification claims without valid documentation.
Avoiding these mistakes ensures uninterrupted compliance.