NOP Import Certificate requirements for US organic sales grace period ended September 19, 2024. Are you ready? Click here.

New: Rules, Standards, Analysis, and NOSB Members

“You may have a fresh start any moment you choose, for this thing that we call ‘failure’ is not the falling down, but the staying down.”   ~Mary Pickford

Featured Topic

Wheat, Chaff, and Grist for the Organic Mill

Rather than make sweeping predictions for 2025, we’d like to offer some gleanings from our work with organic sector clients in 2024.

1. Prioritize cutting-edge technology to scale your business.
Organic brands, farms, and manufacturers who harnessed real-time tracking systems and cloud-based platforms were able to function more nimbly in an increasingly unpredictable environment.

2. Embrace uncertainty.
Plan for anything, as opposed to everything. With political instability (near and far), climate volatility, shifting tariffs and regulatory changes, contingency planning is a critical priority for 2025. Operators who built their supply chains and markets to be resilient and responsive suffered less, or even thrived.

3. Localize supply chains to enhance flexibility.
Overly centralized supply chains led to significant challenges for some companies. Cultivating suppliers and manufacturers closer to your markets can mitigate delays, adapt to changing consumer behaviors, and reduce production costs. Consider a diversified supplier portfolio, and pre-ordering and holding ingredients, to maintain continuity, as this trend is expected to persist into 2025.

4. Stay on top of regulatory trends.
SOE brought into sharp focus the need for a return to sound and sensible approaches to certification policy, processes, inspections, and risk management. Strengthening Organic Enforcement (SOE) brought change to 100% of certified operations and is bringing thousands more into the certification fold. SOE derivatives will continue to not-so-subtly ripple through 2025.
International regulatory changes matter to the U.S. organic market, and more are coming. Vigilance will pay dividends for the organic sector.

5. Buckle up.
With the incoming administration, increased import tariffs are likely. We’ll have to wait and see what that does for ingredient sourcing. Our hope is that tariffs function as negotiation tools rather than immediate policy changes. Whatever the future holds, we’ll be here to face it, together. With the incoming administration, increased import tariffs are likely. We’ll have to wait and see what that does for ingredient sourcing. Our hope is that tariffs function as negotiation tools rather than immediate policy changes. Whatever the future holds, we’ll be here to face it, together.

Organic Regulatory Updates

Final Rule: Organic Mushrooms and Pet Food
All organic mushroom and pet food operations must comply with the new rules no later than February 22, 2027.

The new rules:

  • Clarify which crop production standards mushroom producers should use, and which new requirements should be followed for mushroom substrate and spawn used in mushroom production.
  • Standardize existing practices in organic pet food handling by applying the regulations for organic processed products to pet food.
  • Allow the synthetic amino acid taurine to be used in organic pet food.

New National Organic Standards Board Members Announced
The USDA appointed five new members of the National Organic Standards Board for five-year terms beginning this month. Congratulations!

Handler seats:

  • Kathryn Deschenes (Colorado), Director of Regulatory Affairs at Danone.
  • Amanda Felder (California), Organic Integrity and Environmental Compliance Manager at Taylor Farms.

Retailer seat:

  • Andrea Hatziyannis (Arizona), Category Strategy Manager for Sprouts Farmers Market

Environmental Protection and Resource Conservation seat:

  • Cathleen McCluskey (Wisconsin), Policy and Advocacy Director for Organic Seed Alliance.

Farmer seat:

  • Corie Pierce (Vermont), Owner and Operator of Bread & Butter Farm, a 600- acre diversified organic vegetable and grass-fed beef and pork farm.

Understand Organic Certificates Like a Boss
Learn how to use the USDA Organic Certificate, to understand an operation’s certification status and which products and practices are certified via Overview of the USDA Organic Certificate—the latest microlearning course from the USDA Organic Integrity Learning Center. Familiarity with the details on the certificates will help your business stay maintain regulatory compliance and protect organic integrity.

International News

Changes to Canada’s Organic Standards Expected
The Canadian General Standards Board Technical Committee on Organic Agriculture will release a draft of proposed changes to the Canadian Organic Standards this spring for public comment.

Potential changes include:

  • Further defining responsible tillage, and adding record-keeping for tillage events
  • Adding struvite (magnesium ammonium phosphate) from processed municipal wastewater to the Permitted Substances List (PSL) as a source of phosphorus for crop production
  • More specific environmental enrichment requirements for livestock kept indoors
  • Encouraging biodiversity in maple production by requiring at least 20% of the volume of wood within the sugar bush to consist of companion species
  • A new detailed section on producing organic insects

Other topics:

  • Palm oil requirements will not change.
  • No addition of social justice requirements, as they fall outside the scope of the Canadian Food Inspection Agency, which oversees the organic standards.

EU Bans BPA in Food Packaging
The European Union has banned the use of Bisphenol A (BPA) in food contact materials, due to its potentially harmful health impact. BPA will not be allowed in products that come into contact with food or drink, such as the coating on metal cans, reusable plastic drink bottles, water distribution coolers and other kitchenware.

For most products, there will be an 18-month phase out period, with very limited exceptions where no alternatives exist, to allow industry time to adapt and avoid disruption in the food chain. The ban also includes other bisphenols that are harmful to the reproductive and endocrine systems. BPA is already banned in the EU for infant bottles and similar products.

Global Organic Textile Standards Up for Public Review
Stakeholders can comment on proposed changes to the Global Organic Textile Standards (GOTS) until March 7.

New Zealand and China Update Organic Agreement
Updates to the Mutual Recognition Arrangement between China and New Zealand are expected to strengthen trade, especially exports of New Zealand’s organic bulk food service ingredients, and streamline certification. China has similar recognition agreements with Australia and Denmark.

Indonesia’s GM Food Labeling Laws Changed
Foods determined to be Genetically Modified Gene Edited food by Indonesia’s GM Products Biosafety Commission will be required to obtain approval and safety certification from Indonesia’s Food and Drug Authority (BPOM). To address potential food safety concerns, information about the origin of the donor organism DNA is also required.

Inside the Beltway

Take Action to Restore Organic Program Funding
Although Congress funded the government through March 2025 and extended the Farm Bill until September 2025, some essential organic programs were left out of the spending package that passed on December 21. Organic programs left unfunded include:

  • Organic Certification Cost Share Program (OCCSP), which offsets certification costs for farmers and processors.
  • Organic Data Initiative (ODI), which collects data to support organic agriculture
  • Organic Certification Trade and Tracking Program (OCTT), which provides infrastructure to enforce organic regulations and prevent fraud

To help restore funding for these programs, contact your legislators.

How Will the Administration Change Impact Organic Regulations?
The Organic Trade Association outlined some of the contingencies, including the potential to rescind any regulations published from approximately August 1, 2024 until Inauguration Day January 20. The Market Development for Mushrooms and Pet Food rules, published December 23, fall into that period. Further progress on two organic rules on USDA’s agenda—Pesticides for Organic Production and Nitrogen Fertilizers for Crops—depend on the priorities of the new administration.

Build Business with a Grant
Small and mid-sized food and farm businesses can apply for Business Builder Grants of up to $100,000 for business, market and supply chain development projects. Administered through regional food business centers across the country, grant application deadlines vary.

Mustard Greens the Latest Gene-Edited Crop?
Based on the Food and Drug Administration list of new plant variety meetings and consultations, gene-edited mustard greens and apples may soon be headed to a farms and tables. The FDA provides voluntary premarket meetings and consultations for new foods from genome-edited plants; meetings are used for lower-risk foods and consultations are used for foods that may be more likely to raise safety or regulatory considerations.

The Survey Says…

New Analysis Bolsters Mexico’s Ban on GM Corn
After a review of the scientific literature, Mexico’s National Council for Humanities, Science and Technology (CONAHCYT) concluded that there is ample evidence to restrict the use of genetically modified corn and glyphosate in the country’s food supply as a precaution. Corn is a staple food of Mexicans, who consume 1-2 pounds of it per day. Animal studies have linked GM corn to effects on male fertility, immunological alterations, kidney and liver toxicity and damage to the digestive system, liver and pancreas.

Do Spaniards Trust Environmental Certifications?
Spaniards’ consumption of organic products has been relatively stable over the past five years, according to the ClicKoala 2024 Sustainable Consumption Report. Thirteen percent of Spaniards consume organic foods regularly. Among young people, 23% identified a sustainable lifestyle as a key component of their identity, down from 45% in 2019. Trust in certificates that guarantee environmental or labor-friendly practices is at 46% across the population, but is down 9 percentage points since 2019. The change is attributed to an overabundance of labels, leading to mistrust and confusion.

Organic Industry News & Notices

OMRI Revised its Standards Manual
The Organic Materials Review Institute revised its Standards Manual, including its Generic Materials List, effective January 15, 2025. Key changes include:

  • Processing and Handling use classes will be merged
  • Insect frass category and product review criteria
  • Significant revisions to listing categories for processing and handling, crops, and livestock products.

See the side-by-side comparison, or contact us for details about how these changes might impact your products.

Ample Commodity Supply Keeps Prices Down
Organic commodity prices are expected to continue trending downward, according to reports from the Argus Organic & Identity-Preserved Agriculture Forum. US organic soybean production was down 7%, thanks to carry overstocks and a decline in acreage. Strong domestic supplies of organic corn are expected to reduce imports by 25%. US organic wheat production is expected to be at an all-time high, with acreage for organic winter wheat up 8% and yields up 1%. Although acreage for organic spring wheat is down 2%, yields are up 5%.

Organic Community

Maine Sea Vegetable Production Gets a Boost
Congratulations to Maine Coast Sea Vegetables, one of Maine’s five recipients of a Resilient Food Systems Infrastructure Program (RFSI) designed to strengthen regional and local food systems. Maine Coast Sea Vegetables in Hancock, Maine, will install and operate a seaweed powder mill to process farm-raised kelp into high-value powder, filling a supply chain gap for Maine’s seaweed growers. funded by President Biden’s American Rescue Plan, the grant is part of a $420 million available nationwide. Maine Coast is one of Wolf & Associates’ oldest and most fun clients.
 
Welcome, Franklin Smith!
The Wolf & Associates team now includes Franklin Smith. Franklin brings over a decade of experience in the natural food industry, with a diverse background spanning farming, processing, certification, sales, and marketing. He has been instrumental in driving growth for organic CPG operations, beginning with Guayaki Yerba Mate and later at Mountain Rose Herbs.
 
For the past three years, Franklin worked in organic certification at Oregon Tilth, where he specialized in client experience and onboarding. In this role, he ensured both new and existing clients received the guidance and resources necessary for a successful certification experience
 
At Wolf & Associates, Franklin focuses on business development and new client intake, helping clients access the support they need to thrive.
 
Franklin lives in Eugene, Oregon with his wife and daughter. When not working to advance the organic industry, he enjoys travel, metalworking, gardening, and meandering through the forests of the Pacific Northwest.