Part 1 · Prelude
A standardized ranking and an investigation answer different questions. The separate Circle H investigation examines authority claims, kosher collaboration, related-party governance, certificate records, and unanswered questions. This article asks a narrower question: how much of Circle H’s organizational capability and accountability can be substantiated under the same eleven metrics applied to every certifier?
The assessment separates control assurance, operational evidence, and publicly verifiable evidence. A valid independent accreditation can substantiate controls that its standard and scope actually assessed, even when the certifier does not publish every underlying record. Government records and other authoritative public sources count in the public-evidence layer even when Circle H does not reproduce them on its website.
Circle H is a real and active nonprofit. New Jersey and official IRS records establish its formation and tax-exempt history, while the newest return identifies Elsayed Zayan as current director, Eman Ali Khashaba as prior director, three independent voting members, no separate stockholder body, and no external approval right [1] [2] [13]. NSF and Nawah independently corroborate current activity and Zayan’s executive role [10] [11]. Circle H also publishes a detailed assessment and certification workflow and individual certificate records [5] [7].
No current credential issued by an identifiable independent accreditation body was verified. Circle H’s own pages and outside announcements use accreditation, authorization, partnership, and recognition language, but the official GAC directory search and earlier institutional checks did not produce a current formal accreditation record [3] [4] [12]. Those bounded searches do not prove that no private agreement or credential exists anywhere. They mean this assessment awards no accreditation-derived control credit unless Circle H supplies the issuer, status, standard, dates, locations, scope, restrictions, surveillance, and independence evidence. This public assessment does not replace the controlling HIPS standard, an accreditation decision, a certification decision, or a religious ruling.
Halal Industry Exposé · Accountability Assessment
Circle H International Organizational accountability: 42% · Grade F · Insufficiently substantiated
Moderate confidence. Circle H receives credit for its verified nonprofit identity, official IRS governance records, two named directors across successive filings, three current independent voting members, no separate stockholder body or external approval right, independently corroborated NSF and Nawah relationships, a detailed published assessment workflow, certificate fields, and operating history. The reviewed record does not identify the other two current voting members, claimed scholars and committees, personnel competence, Islamic decision authority, complete related-party safeguards, current accreditation, reliable certificate status, or formal complaints and appeals controls.
This is an organizational accountability score, not a ruling that every Circle H certificate is invalid, proof that an undisclosed control does not exist, a conclusion that contractor or volunteer staffing is improper, or an inference about any person’s religion. Accreditation credit is awarded only when the issuing body, current status, standard, dates, and scope can be verified.
Halal Certification Body Accountability Assessment version 2.1. Source cutoff September 11, 2026. Last reviewed September 11, 2026. Raw score 41.83 out of 100.
Accreditation examined
No current accreditor verified · Not verified. Not verified. Not verified. Accredited Not verified; expiry Not verified.
Scope: Circle H uses accreditation, authorization, partnership, and recognition language, but no current credential issued by an identifiable independent accreditation body was verified. A direct GAC directory search and earlier official-institution searches did not identify a current formal accreditation record. Those bounded searches do not prove that no private agreement or credential exists anywhere; they support awarding no accreditation-derived control credit until the issuer, standing, standard, dates, locations, scope, restrictions, and surveillance are verified.
Third-party independence: No accreditation body was verified for Circle H, so accreditor independence cannot be assessed and no accreditation assurance is transferred into the metric scores.
Status factor 0 percent; scope factor 0 percent; independence factor 0 percent; accreditation assurance factor 0 percent.
How USDHS grades organizational accountability
Each metric is 60 percent control assurance, 25 percent operational evidence, and 15 percent public evidence. Government records and other authoritative public sources count even when the certifier does not reproduce them on its own website. Accreditation supports only the control layer within its verified scope. Classification bands: A, 90 to 100, strongly substantiated; B, 80 to 89, substantiated; C, 70 to 79, partially substantiated; D, 60 to 69, material gaps; F, 0 to 59, insufficiently substantiated.
Part 2
Numbered assessment metrics
1. Legal identity and operating status
Legal entity, jurisdiction, operating identity, formation, status, address, and required registrations.
5.51 of 7 points. verified.
Accreditation effect: No accreditation-derived credit was available; government and IRS-derived records provide strong direct evidence.
- A. Control assurance, 60 percent
- 75 percent evidence factor; 3.15 points. New Jersey and official IRS records establish a domestic nonprofit, formation timeline, EIN, federal tax exemption, and continuing filings; the IRS return’s LLC wording should be reconciled with the public Inc. name.
- B. Operational evidence, 25 percent
- 75 percent evidence factor; 1.31 points. Current certificate pages and independent 2026 relationships corroborate continuing operation.
- C. Public evidence, 15 percent
- 100 percent evidence factor; 1.05 points. Government and IRS records publicly expose the legal name used in the return, EIN, filing period, mailing address, exempt status, and officer information even though Circle H does not reproduce all of those fields on its website.
Metric conclusion: Circle H’s legal identity and continuing operation are strongly substantiated.
2. Ownership and control
Beneficial owners, percentages, controlling persons, governance rights, related parties, and conflicts.
6.88 of 10 points. partially verified.
Accreditation effect: No current independent accreditation or complete governing record was verified.
- A. Control assurance, 60 percent
- 75 percent evidence factor; 4.50 points. The official IRS return identifies one current director, one prior director, three independent voting members, no separate membership or stockholder body, no outside election right, no external approval right, and no reported related-organization control; as a nonprofit, equity percentages are not applicable.
- B. Operational evidence, 25 percent
- 50 percent evidence factor; 1.25 points. Elsayed Zayan’s executive role is independently corroborated, successive IRS filings identify director transitions, and the newest filing records a three-person voting body; the other two members and recusal records remain unavailable.
- C. Public evidence, 15 percent
- 75 percent evidence factor; 1.13 points. Official IRS data publicly identifies the current and prior directors, three independent voting members, absence of separate stockholders and external approval rights, no reportable compensation, and staffing figures; the other two members and bylaws are not public.
Metric conclusion: Nonprofit control is substantially visible through official IRS records, while the other two voting members, bylaws, internal appointment rules, and certification-specific related-party safeguards remain incomplete.
3. Governance and accountable leadership
Named leadership, governing bodies, organizational structure, management responsibility, and accountable contacts.
5.50 of 8 points. partially verified.
Accreditation effect: No accreditation-derived assurance of governance controls was available.
- A. Control assurance, 60 percent
- 75 percent evidence factor; 3.60 points. Circle H describes trustees, an executive committee, a Sharia council, sector committees, and a consultancy committee, while official IRS filings verify successive directors and a three-member independent voting body.
- B. Operational evidence, 25 percent
- 50 percent evidence factor; 1.00 points. Independent announcements corroborate Zayan’s executive role, and the IRS return confirms a board transition and current governance count, but not the wider committees in operation.
- C. Public evidence, 15 percent
- 75 percent evidence factor; 0.90 points. Government filings publicly identify the current and prior directors and current voting-member count; the other two members, trustees, councils, committee rosters, mandates, and terms remain unnamed.
Metric conclusion: Accountable leadership and a governing-body count are publicly substantiated, while the other two members and claimed councils and committees remain incomplete.
4. Personnel competence and authorization
Auditor, reviewer, technical-expert, and contractor qualifications, training, authorization, monitoring, and assignments.
3.50 of 14 points. partially verified.
Accreditation effect: No current accreditation or independent competence evaluation was verified.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 2.10 points. Circle H describes specialized assessment teams and technical experts, but no competence procedure, roster, authorization scope, or monitoring system was reviewed.
- B. Operational evidence, 25 percent
- 25 percent evidence factor; 0.88 points. Certificates and partnerships imply personnel activity without identifying who audited, reviewed, or decided specific files.
- C. Public evidence, 15 percent
- 25 percent evidence factor; 0.53 points. The claimed scholars, committees, auditors, technical experts, reviewers, qualifications, and assignments are not named.
Metric conclusion: Personnel functions are claimed; competent and authorized individuals are not substantiated.
5. Islamic authority and halal decision
Qualified Islamic-affairs personnel, governing authority, jurisprudential basis, review roles, and final halal decisions.
3.25 of 13 points. partially verified.
Accreditation effect: No accreditation-derived assurance of Islamic governance or decision authority was available.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 1.95 points. Circle H describes a Sharia Executive Committee, Advisory Council, and sector committees, but no governing appointments or externally verified mandates were reviewed.
- B. Operational evidence, 25 percent
- 25 percent evidence factor; 0.81 points. Circle H says the Sharia Advisory Council is consulted when needed, without identifying a case-level reviewer or final decision authority.
- C. Public evidence, 15 percent
- 25 percent evidence factor; 0.49 points. Council members, claimed scholars, qualifications, jurisprudential procedure, review responsibility, and the final halal decision-maker are not identified.
Metric conclusion: A Sharia governance model is described; attributable qualified authority and file-level decisions are not.
6. Halal audit method and facility verification
Application, scope review, documents, on-site work, ingredients, processes, findings, corrections, reports, surveillance, and recertification.
8.60 of 16 points. partially verified.
Accreditation effect: No accreditor-issued standard or scope was verified, so public and operating evidence carry the full burden.
- A. Control assurance, 60 percent
- 50 percent evidence factor; 4.80 points. Circle H publishes a detailed workflow covering application, scope, assessment, reporting, consulting, training, certification, renewal, withdrawal, and expiry.
- B. Operational evidence, 25 percent
- 50 percent evidence factor; 2.00 points. Public certificates and independent relationships show activity, but no representative audit reports, corrective records, personnel assignments, or final decisions were reviewed.
- C. Public evidence, 15 percent
- 75 percent evidence factor; 1.80 points. The process is detailed, while initial site-visit requirements, surveillance frequency, responsible personnel, religious review, and independent decision control remain unclear.
Metric conclusion: Circle H publishes a substantial process, but the accountable file-level implementation and mandatory on-site controls remain incomplete.
7. Impartiality and decision separation
Conflicts, consultancy separation, impartiality oversight, and separation among audit, review, and certification decisions.
2.88 of 10 points. partially verified.
Accreditation effect: No independent accreditation or impartiality assessment was verified.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 1.50 points. Circle H describes multiple governing and consulting bodies but publishes no complete impartiality policy, oversight mandate, or decision-separation rule.
- B. Operational evidence, 25 percent
- 25 percent evidence factor; 0.63 points. The NSF agreement states the organizations remain independent, but no Circle H file-level separation or CH Group recusal record was reviewed.
- C. Public evidence, 15 percent
- 50 percent evidence factor; 0.75 points. The official IRS return publicly states that no conflict-of-interest policy was in place; assessment, consulting, training, and certification remain marketed together without complete independent approval safeguards.
Metric conclusion: The absence of a reported conflict policy is publicly verifiable, while impartial certification decision and related-party recusal controls remain insufficiently substantiated.
8. Standards, scheme, and certification scope
Governing standards, sectors, locations, exclusions, religious positions, certificate scope, and scheme boundaries.
2.45 of 7 points. partially verified.
Accreditation effect: No accreditor-issued scope or governing certification-body standard was verified.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 1.05 points. Circle H claims proprietary standards across eight sectors and publishes general halal positions without a controlled standard version or externally verified authority.
- B. Operational evidence, 25 percent
- 50 percent evidence factor; 0.88 points. Public certificate pages identify holders, products or services, numbers, and dates across multiple sectors.
- C. Public evidence, 15 percent
- 50 percent evidence factor; 0.53 points. Sectors and general requirements are public, while the governing standard text, revision controls, exclusions, and consistent certificate-level references are not.
Metric conclusion: Certificate scope is visible in samples; the governing scheme and recognized boundaries are not.
9. Certificate traceability and mark control
Current certificate verification, identifiers, holders, sites, products, dates, status changes, and mark misuse controls.
1.31 of 7 points. contradicted.
Accreditation effect: No independently evaluated directory or mark-control system was verified.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 1.05 points. Circle H describes QR and search verification, while no complete active, expired, suspended, withdrawn, replaced, or misuse-control register was reviewed.
- B. Operational evidence, 25 percent
- 0 percent evidence factor; 0.00 points. Two sampled pages remained labeled Valid Halal Certificate after the expiry dates displayed on those same pages had passed.
- C. Public evidence, 15 percent
- 25 percent evidence factor; 0.26 points. Certificate pages expose useful fields, but the contradictory validity labels prevent reliable current-status verification.
Metric conclusion: The directory exposes records but failed the sampled current-status test.
10. Complaints, appeals, and corrections
Complaint and appeal routes, timing, independent review, records, corrections, escalation, and non-retaliation.
0.15 of 4 points. partially verified.
Accreditation effect: No accreditation-derived assurance of complaint and appeal controls was available.
- A. Control assurance, 60 percent
- 0 percent evidence factor; 0.00 points. No formal complaint, appeal, independent disposition, escalation, non-retaliation, correction-log, or response-time procedure was reviewed.
- B. Operational evidence, 25 percent
- 0 percent evidence factor; 0.00 points. No complaint, appeal, correction, or outcome record was available.
- C. Public evidence, 15 percent
- 25 percent evidence factor; 0.15 points. A general email contact exists, but it is not a complete complaints and appeals procedure.
Metric conclusion: A contact route exists; the formal accountability system and operating record do not.
11. Operating history and demonstrated capacity
Corroborated timeline, current activity, clients, sectors, personnel resources, and workload matched to competent capacity.
1.80 of 4 points. partially verified.
Accreditation effect: No accredited scope or resource evaluation was verified.
- A. Control assurance, 60 percent
- 25 percent evidence factor; 0.60 points. Circle H claims extensive scholarly, committee, audit, and international capacity without publishing the accountable personnel and resource system.
- B. Operational evidence, 25 percent
- 75 percent evidence factor; 0.75 points. Incorporation, IRS filings, certificate pages, NSF, and Nawah corroborate activity from 2020 through 2026.
- C. Public evidence, 15 percent
- 75 percent evidence factor; 0.45 points. Circle H publishes sectors, process, certificates, and relationships, while the personnel and contractor capacity behind the claimed workload remains unidentified.
Metric conclusion: Operating activity is well corroborated; qualified capacity for the claimed scale is not.
Part 3
Conclusion
Strongest findings
- New Jersey and official IRS records verify Circle H’s legal identity, 2020 formation timeline, tax-exempt status, and continuing filings, while the IRS return uses LLC terminology that should be reconciled with the public Inc. name.
- The official 2025 IRS return identifies Elsayed Zayan as current director, Eman Ali Khashaba as prior director, three independent voting members, no separate members or stockholders, no external approval right, no reportable compensation, no employees, and three volunteers.
- NSF and Nawah independently corroborate current activity and Zayan’s executive role.
- Circle H publishes a detailed application, assessment, reporting, consulting, training, certification, renewal, withdrawal, and expiry workflow.
- Public certificate pages expose holders, scopes, identifiers, issue dates, and expiry dates.
Material gaps
- The other two current voting members, claimed scholars, committee members, auditors, technical experts, Islamic reviewers, and certification decision-makers are not identified.
- Personnel competence, authorization, monitored assignments, and accountable Islamic decision authority are not substantiated.
- The IRS return says no conflict-of-interest policy was in place, while consulting and certification are described within one framework without complete independent decision-separation safeguards.
- No current independent accreditation credential, complete complaint-and-appeal procedure, or reliable certificate-status history was verified.
- Sampled certificate pages continued to say Valid Halal Certificate after their displayed expiry dates.
Unresolved questions
- Who are the other two current voting members, and who are the trustees, scholars, committee members, auditors, reviewers, and certification decision-makers?
- What qualifications, authorization scopes, monitoring, and assignments govern those personnel?
- Which current accreditation body, if any, has assessed Circle H, under what standard and scope?
- How are consulting, training, assessment, Islamic review, technical review, and certification decisions separated?
- Who approved certification involving CH Group, and what recusal and independent-review controls applied?
- How does Circle H prevent expired, suspended, withdrawn, or replaced certificates from appearing valid?
Critical-control caps
- As a nonprofit, Circle H has no equity percentages to disclose. Official IRS filings identify one current director, three current independent voting members, no separate stockholder body, and no external approval right, but do not identify the other two members or complete internal appointment authority; a higher result would be capped at D until controlling membership and authority are substantially identified.
- Personnel competence, Islamic authority, halal audit method, and decision separation earned 18.225 of 53 points, or 34.39%; the core-control cap fixes the maximum grade at F.
Material records are rescored under the same rules, whether they raise or lower the result. Documentary evidence may be sent to director@halalstandards.org.
Frequently asked questions
Why does Circle H receive 42%, Grade F?
Official IRS records add substantial credit by identifying successive directors, three independent voting members, the absence of a separate stockholder body or external approval right, staffing figures, and the absence of a conflict-of-interest policy. The result remains Grade F because personnel competence, Islamic authority, decision separation, accreditation, reliable certificate-status controls, and complaint procedures remain insufficiently substantiated.
Is Circle H currently accredited?
No current accreditation-body directory entry, certificate, number, governing standard, validity period, or scope schedule was verified. Circle H may change that finding by identifying the issuing independent accreditation body and supplying a current credential with its scope, dates, locations, restrictions, and surveillance status.
Does the score mean Circle H is inactive or every certificate is invalid?
No. Current activity is independently corroborated, and contractor or volunteer staffing can be legitimate. The score concerns how much of the organization’s controls and accountability are substantiated; it does not invalidate every certificate or prove undisclosed controls do not exist.
Why is this separate from the Circle H investigation?
The investigation examines documented authority claims, partnerships, practices, certificate records, and conflicts. This ranking applies a standardized organizational method. Keeping them separate prevents the investigation from being mistaken for the scoring formula.
Can Circle H’s score change?
Yes. USDHS will rescore material authoritative evidence under the same control, operational, and transparency layers. New evidence may raise or lower the result, and substantive corrections will be dated.
References
- New Jersey Division of Revenue, Business Name Search
- IRS-derived Circle H International nonprofit filings
- Circle H International, About
- Circle H International, Sharia Council
- Circle H International, Certification Process Overview
- Circle H International, Halal Governance
- Circle H International, Certification Verify System
- Circle H International, Gourmet Kosher Management certificate page
- Circle H International, Micsafe Medical Group certificate page
- NSF and Circle H strategic collaboration
- Nawah Scientific and Circle H announcement
- GCC Accreditation Center, Accredited Bodies
- IRS, Form 990 Series Downloads and official 2025 Circle H return (object 202611119349301856)