Handling self-declared suspensions without losing anniversary dates

Regulatory framework for voluntary self-declared suspensions

Certificate holders occasionally face temporary operational difficulties that prevent full compliance with certification requirements. Section 7.4.3.3 a of the GLOBALG.A.P. General Regulations permits producers to voluntarily request a self-declared suspension for one, several, or all certified products. This mechanism provides producers with structured time to rectify non-conformances before an external certification body imposes a formal sanction.

This regulatory provision applies to Option 1 individual producers, Option 1 multisite operations, and Option 2 producer group members. However, a producer may only declare a voluntary suspension if a certification body has not already issued a warning or suspension for the same non-conformance. Quality managers and compliance leads must act proactively to initiate self-suspension before an external audit detects the non-compliance.

Operational constraints and anniversary date retention

A critical aspect of voluntary self-declared suspensions is the preservation of the certification cycle. Section 7.4.3.3 b dictates that a voluntary suspension does not delay the certificate renewal date or waive applicable system participation fees. The twelve-month certification anniversary date remains fixed regardless of how long the product remains voluntarily suspended.

While a product is under self-declared suspension, strict commercial restrictions apply across all operations. Section 7.4.3.2 h mandates that producers must immediately cease using trademarks, logo claims, and certificate credentials for the suspended product stream. In addition, Section 5.2.3 b prohibits sanctioned or suspended producers from transferring their registration to another certification body until all outstanding non-conformances are formally resolved.

Protocol for declaring and lifting voluntary suspensions

Initiating and closing a self-declared suspension requires formal coordination between the certificate holder and the managing authority. Section 7.4.3.3 e requires the certification body or producer group to update the product status to self-declared suspension within the official IT platform. Section 7.4.3.3 c specifies that the deadline for implementing corrective actions is established by mutual agreement between the producer and the certification body.

Lifting a self-declared suspension depends on thorough verification of implemented corrective actions. Section 7.4.3.2 i permits the certification body to evaluate corrective evidence through either off-site document reviews or on-site follow-up audits. Under Section 4.6 i of the Quality Management System rules, producer groups hold direct authority to lift self-suspensions for their members once internal auditors confirm compliance. If non-conformances remain unresolved past the agreed deadline or the maximum twelve-month limit, Section 7.4.4 a iii mandates contract cancellation.

Comparison of voluntary self-declared and CB-imposed suspensions

| Regulatory aspect | Voluntary self-declared suspension | CB-imposed sanction suspension | | Initiation source | Requested voluntarily by the certificate holder or group member | Imposed by the certification body following an audit non-conformance | | Anniversary date impact | Certificate renewal date and anniversary remain unchanged | Certificate renewal date and anniversary remain unchanged | | Fee obligations | Full system participation fees and CB fees remain payable | Full system participation fees and CB fees remain payable | | Trademark usage | Immediate prohibition on logos, claims, and certificate use | Immediate prohibition on logos, claims, and certificate use | | Maximum duration | Deadline agreed with CB or QMS up to twelve months maximum | Deadline set by CB up to a maximum of twelve months | | Resolution failure | Results in contract cancellation and twelve-month re-entry ban | Results in contract cancellation and twelve-month re-entry ban |

What to do now

• Immediate non-conformance assessment: Evaluate operational failures promptly and determine if a voluntary self-declared suspension is necessary before an external audit.
• Formulate formal suspension requests: Submit a written self-declaration request to your certification body or QMS manager specifying the affected products.
• Establish agreed corrective action deadlines: Negotiate a realistic timeline with your certification body or QMS to complete corrective actions well before certificate expiry.
• Implement strict product segregation: Halt all trademark claims, logo uses, and certified sales for the suspended product stream immediately upon declaration.

Reference documents

• GLOBALG.A.P. general regulations – Rules for individual producers, v6.0_Sep22, Section 5.2.3, Section 7.4.3, Section 7.4.4
• GLOBALG.A.P. general regulations – Rules for producer groups and multisite producers with QMS, v6.0_Sep22, Section 4.6, Section 7.4.3
• GLOBALG.A.P. general regulations – Rules for Certification Bodies, v6.0_Sep22, Section 8.2