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Frequently Asked Questions

  1. What does organic mean?
  2. How can I get my product NOP certified organic? What is required to be certified as a farm, processor, or distributor?
  3. What are the requirements for labeling organic products?
  4. Why doesn’t my product qualify for NOP organic certification?
  5. Does the USDA NOP have regulations for non-food products (e.g., supplements, personal care products, or pet food)?
  6. What exactly does WD+A do?
  7. How can I petition to get a substance listed on the USDA NOP National List?
  8. Where do I go to source raw ingredients for my finished products?
  9. What fair trade, fair labor, or sustainable production certification programs are available?
  10. Do you provide advice on requirements for access to organic markets outside the United States?
1. What does organic mean?

Organic is a label that refers to the way in which food and fiber products are grown and processed. Organic agriculture is a system of farming that maintains and replenishes soil fertility without the use of toxic and persistent pesticides and fertilizers. Organic products must be produced without antibiotics, synthetic hormones, genetic engineering, sewage sludge, or irradiation. In accordance with its founding principles, organic agriculture integrates farming systems with the broader natural system to sustain ecological wellbeing.

The National Organic Program, under the USDA, develops, implements, and administers the U.S. organic standards for production, handling, and labeling of crops, livestock, and processed agricultural products. The standards include a list of approved synthetic and prohibited non-synthetic substances for organic production (National List of Allowed and Prohibited Substances), which can be accessed via this database. Organic growers and handlers must be certified by an “Accredited Certifying Agent” (independent third-party) that has been approved and audited by the USDA.

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2. How can I get my product NOP certified organic? What is required to be certified as a farm, processor, or distributor?

Step 1: Read up. If you have not already done so, spend some time on the National Organic Program Web site, which contains the:

  • NOP Regulations (the organic standards);
  • NOP Program Handbook (explains how the organic standards apply to certain regulated activities);
  • National List of Allowed and Prohibited Substances; and
  • Information for Producers and Handlers Applying for Organic Certification

Step 2: Choose a third-party certifier. Any operation that produces or handles agricultural products intended to be sold or labeled organic must be certified by a USDA-accredited certifying agent. When comparing certifiers, consider their areas of expertise, fees, structure, market access (if you intend to sell overseas), and other services offered (e.g., food safety services, seminars). To maintain independence and integrity, please note that a certifier cannot offer consulting services.

Step 3: Submit an application. Application requirements vary depending on the type of facility (producer or handler) and category (crop, livestock, or processing). Here is a general list of the kinds of records you will need to include in your application:

  • History of Substances―a list of substances applied to your land over the prior three years, with auditable evidence that you have not used a prohibited substance for three years.
  • Organic System Plan―a plan describing your production or handling practices, monitoring activities, procedures to prevent commingling, and recordkeeping.
  • Supporting Documentation―e.g., list of crops, animals, or ingredients; field history; purchase records of inputs; input application records; seed transplant documents; pest and soil management records; health records for livestock; audit trails; and sanitation procedures.

Note: If you have a multi-ingredient finished or processed product, ingredients and processing facilities must be certified to label a product as “Made with Organic,” “Organic,” or “100% Organic.”

Step 4: Submit to onsite inspection. Every organic audit includes an on-site inspection, during which all records must be readily accessible.

Ask the Organic Specialists about certification. We have worked on hundreds of organic projects and can answer all of your questions related to organic system plans, readiness, process, compliance, and domestic and international requirements. And we also provide training for personnel.

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3. What are the requirements for labeling organic products?

Organic nutrition labelOrganic and its derivations can be used only on certified organic products and ingredients. There are three organic labels:

  • 100% Organic―If a product contains all organically produced ingredients, it may carry both the USDA Organic seal and a 100% Organic claim.
  • Organic―If a product is made with at least 95% organic ingredients and the remaining ingredients are approved for use in the National List, it may carry the USDA Organic seal with an Organic claim.
  • Made With Organic―If a processed product contains at least 70% organic ingredients (and the remaining 30% meet specific criteria), it may list up to three ingredients or categories.
  • Less than 70% Organic―If the product contains less than 70% organic ingredients, you can use organic on the ingredient statement.

“Transition to Organic” claims are not allowed. For more detailed information on labeling, review this NOP presentation, or Ask the Organic Specialists.

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4. Why doesn’t my product qualify for NOP organic certification?

There are many reasons a product may not be eligible for NOP certification. Here are some examples:

  • The product does not meet the NOP regulations.
  • The product is an input or processing aid. (The Organic Materials Review Institute, EPA, Accredited Certifying Agents, and others―not the NOP―determine whether or not an input qualifies for use in organic production and processing.)
  • The product is fish, which does not qualify for organic certification at this time.
  • The product is a finished textile, which also does not qualify; however, cotton and flax do qualify.
  • The product contains 95% organic ingredients, but also contains a non-organic agricultural ingredient or processing aid that is not allowed for use.

As you can see, there are lots of scenarios and nuances in determining whether or not a product meets the organic standards. Ask the Organic Specialists to help you locate the right ingredient, determine if you can change a formulation, or help petition―if appropriate―to get an ingredient approved for inclusion on the National List.

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5. Does the USDA NOP have regulations for non-food products (e.g., supplements, personal care products, or pet food)?

Cosmetics―If you can produce your cosmetic products using organic agricultural practices and allowable food processing aids and additives, then you can qualify for NOP certification under either the Organic or Made with Organic label. If not, you might like to consider the NSF/ANSI 305 Personal Care Standard. This private initiative also requires NOP certified ingredients, but it allows such ingredients to undergo certain chemical processes that are considered synthetic under the NOP.

Textiles―While the NOP does not have a textile processing or manufacturing standard, fibers certified to NOP crop standards can be recognized in Made with Organic Cotton (or other fibers) label claims (not advertising claims). Textile products that are produced in accordance with the Global Organic Textile Standard (GOTS) may also be sold as organic in the U.S., but may not refer to NOP certification or display the USDA organic seal.  For more information on making organic textile claims across the supply chain, see the Global Organic Textile Standard (GOTS), or Ask the Organic Specialists.

Pet Food―Currently, USDA organic certification for pet foods follows the organic standards for human food products. Please note, however, that the FDA has many nutritional supplementation requirements that are not allowed under the NOP. Ask the Organic Specialists whether or not your pet food product meets current NOP requirements for an Organic or Made with Organic claim.

Supplements―At present, supplements can be certified organic if they comply with the current national organic standards. Please note that the National List is written for foods, not supplements, and does not cover all of the ingredients and processing aids required for supplement processors. Ask the Organic Specialists to determine whether or not your formulation would qualify and, if so, for what organic labeling claim.

Fish―The USDA NOP does not currently maintain standards for farm or wild caught fish. The National Organic Standards Board, however, has developed organic standards for farmed fish, but these standards have not yet been published as regulations. Fish certified to another organic standard may be labeled organic in the United States, but not in California or Georgia.

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6. What exactly does WD+A do?

For a description of WD+A services, click here.

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7. How can I petition to get a substance listed on the USDA NOP National List?

National List amendments are based on recommendations by the National Organic Standards Board. For a detailed description on how to initiate a petition process, see the NOP Notice of Guidelines on Procedures for Submitting National List Petitions as well the National List Materials Review Process.

Realistically, the petition process takes two to four years, as the petition makes its way through the NOP, NOSB technical review, public comment period, and final ruling. The substance may not be used under the organic standard until final approval. A ruling may include a restriction―e.g., the substance may only be used in a made with organic claim.

Ask the Organic Specialists for advice on effective petitioning, trends, timing, potential barriers, likely opinions of NOSB members, and the nuances of successful petitions.

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8. Where do I go to source raw ingredients for my finished products?

Raw ingredient sourcing is client and sector specific. Ask the Organic Specialists to assist with supply chain security. See our case story on Peak Organic Brewery.

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9. What fair trade, fair labor, or sustainable production certification programs are available?

strawberries growingMore and more companies are interested in implementing and promoting sustainable practices throughout their agricultural operations. At this time, there are a handful of different programs against which you can benchmark your environmental, social, and economic performance. Ask the Organic Specialists about the options and to facilitate a strategic discussion on the pros and cons of each, given your specific business objectives.

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10. Do you provide advice on requirements for access to organic markets outside the United States?

Requirements vary by country. For an overview, see this NOP information sheet: Identifying, Importing, and Exporting Organic Products. In February 2012, the U.S. and European Union signed a landmark trade arrangement that recognizes the U.S. National Organic Program regulations and the European Union organic regulations as equivalent.  Click here to view a summary fact sheet.  For additional information on your requirements and country-specific regulations, Ask the Organic Specialists. We have vast expertise working on organic standards around the world including the EU, Canada, Japan, Korea, Taiwan, and others. We can also provide valuable advice on the kinds of issues you will encounter exporting to a specific country―including the ingredient supply chain―so you can plan accordingly.

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