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

Standards Delay | New NOP Leaders | Who Trusts Organic?

“The most common way people give up their power is by thinking they don’t have any.”    ~Alice Walker

Spotlight

Rumblings from the Road

The organic sector continues to experience strong consumer demand, yet uncertainties loom as the political landscape shifts. Although organic sales likely crossed the $70B mark in 2024, new policy directions under the current administration are already diminishing program and employee certainty, enthusiasm for regulatory compliance, and research essential to our industry’s growth.

While today it appears that Transition to Organic Partnership Program (TOPP) funds are said to be available, we hear many reports that obligated funds are not being reliably dispersed. Although urban organic farming is gaining traction–with cities like Atlanta turning unused spaces into productive farmland–these initiatives need stable policies and funding to thrive and be sustainable.

Additionally, global regulatory inconsistencies and evolving programs remain a challenge. European Union’s (EU) ongoing evolution from an equivalency model to one of compliance continues to be a dynamic system causing uncertainties in many production areas. EU’s deforestation prevention regulations are sure to reshape global supply chains, and ongoing trade negotiations could affect organic imports and exports. 

Perhaps most concerning is the growing scrutiny around the health benefits of organic food and farming, with some scientific authorities questioning past studies even as more studies continue to demonstrate health value. This underscores the need for continued research coupled with strong advocacy to defend organic integrity.

With shifting policies and market pressures, our role as an industry is clear: We must engage actively with regulators, support scientific research, and push for policies that sustain organic agriculture. Fighting to improve the status quo is in our organic DNA, and though the road ahead is uncertain, our collective efforts will determine the future of the movement. We’re so happy to be part of the conversation.

We have a strong suspicion that the upcoming NOSB meeting will be held virtually instead of in-person. We’ve got our eye on the situation and will provide updates as soon as we know more. Stay tuned.

Regulatory Updates

Mushroom and Pet Food Standards Implementation Delayed

USDA’s Agricultural Marketing Service has issued a “regulatory freeze pending review” for the “Market Development for Mushrooms and Pet Food” final rule. Initially published in the Federal Register on December 23, 2024, the rule is based on years of shared community input and discussion.

Announced February 10 in the Federal Register, the “review” pushed effective date of the regulations from February 21, 2025 to March 21, 2025.

Our take: Of course, the situation is (as they say) fluid, so stay tuned, and don’t scrap those updated organic system plans just yet. A defined regulatory framework encourages investment, innovation, and bolsters consumer confidence in organic pet food and mushroom products, so let’s hope this delay is a temporary one. And, having organic pet foods will improve US organic farm margins by providing a value-add market for crop byproducts and seconds. We’ll post updates via LinkedIn and our newsletter as information becomes available.

Leadership Changes at USDA

Starting February 3, the Deputy Administrator of the National Organic Program, Dr. Jenny Tucker, rotated out of that position to serve as the Deputy Administrator of the Specialty Crops Program while that program’s Deputy Administrator, Christopher Purdy will lead the National Organic Program for the next year.

Jenny Lester Moffitt, a staunch organic advocate, resigned from her role as Under Secretary for Marketing and Regulatory Programs effective January 20. She will serve as Senior Fellow at American Farmland Trust.

Brooke Rollins was approved as Secretary of Agriculture.

Our take: We look forward to working with the new NOP Deputy Administrator, and all new USDA personnel. Inspired by the work of Jenny Tucker and Jenny Lester Moffitt, we’ll keep encouraging policies that lead to healthier soil and more opportunity for the organic sector.

California Defines Regenerative Agriculture

On January 7, California’s State Board of Food and Agriculture approved a definition of regenerative agriculture for state policies and programs, pending a few minor changes. The definition is not designed for certification purposes.

Our take: Although the definition mentions organic production systems as an example of regenerative practices, it lacks specifics and accountability mechanisms. The upshot is likely further consumer confusion and greenwashing.

European Union Bans Bisphenol A in Food Contact Materials

The European Union has banned bisphenol A in food contact materials with a phase-in period of one to three years depending on the product.

Phase-in periods:

  • Single-use, final food contact articles manufactured using BPA may be placed on the market until July 20, 2026.
  • Final food contact articles manufactured using BPA may be placed on the market until July 20, 2028, if they are intended for the preservation of fruits or vegetables (except fruit juices) and fishery products.
  • Single-use final food contact articles on which a varnish or coating manufactured using BPA has only been applied to the exterior metal surface may be placed on the market until July 20, 2028.

Our take: The EU has been a leader in removing these materials from the food packaging system, and their ban will make an impact on the types of packaging that are available worldwide.

The Survey Says…

Our New Analysis Examines Pesticide Residue Testing

A Risk-Based Approach to Pesticide Residue Testing in Organic Certification,” a new analysis prepared by our team at Wolf & Associates recommends pesticide residue sampling protocols that address the realities of unavoidable residual environmental contaminations while maintaining the integrity of the National Organic Program and minimizing the burden on farmers. Bill Wolf presented the paper to the Accredited Certifiers Association, and looks forward to feedback on the proposal.

Our take: Something needs to be done to streamline testing protocols and investigations in order to take into account de minimus levels of drift and unavoidable residual environmental contamination (UREC). This proposal makes sense, is based on risk-analysis, and maintains integrity.

Biochar Remediates DDT Contamination

DDT-contaminated soil, resulting from widespread use of the insecticide in the 1950s and 60s, continues to plague some parts of the world. Researchers from Sweden’s Chalmers University of Technology have found that use of biochar helps reduce the toxicity of the soil. In their research on a DDT-contaminated former tree farm in Sweden, soil organisms—including earthworms–took up 50% less DDT when biochar was added to the soil, reducing bioaccumulation of DDT in the food chain.

Our take: Organic farming prioritizes soil health. Understanding how biochar contributes to a healthy ecosystem could be a boon for many, and protects our hard-working earthworms.

Report Examines Cotton and Pesticide Use

The Organic Center’s report “Pesticide, Fertilizer and Genetic Modification Use in Conventional Cotton in the U.S. and Globally: The Case for Organic” found that over 75% of the world’s cotton—the most widely-used natural fiber in apparel and textiles— is genetically modified. Global cotton production uses billions of pounds of pesticides and fertilizers, with roughly 13% of those pesticides classified as highly hazardous the United Nations. Primary author of this report is Sandra Marquardt, an expert and long-time passionate advocate for advancing organic cotton production.

Our take: Organic agriculture, and the ways it can help us reduce health risks, extends far beyond what’s available at the farm stand. Thank you to the Organic Center for your efforts to shed light on all the benefits of organic products.

Young Consumers Trust Organic

A new report from the Organic Trade Association reveals how different generations perceive select label claims, including USDA Organic. “Consumer Perception of USDA Organic and Competing Label Claims,” a survey of 2500 US consumers conducted in October 2024 by Euromonitor International, found that across generations, the USDA Organic label was the most trustworthy of the labels in the survey. Younger consumers, who had the highest levels of trust for the USDA Organic label, were also most willing to pay a premium for organic products—regardless of income level. Nearly 90% of consumers aged 13-28 were already using organic products, making Gen Z a potential driver of organic use for decades to come. Other findings show single attribute claims often have greater influence on what lands in shopping carts, as consumers do not uniformly realize that organic encompasses so many of the single attributes, such as non-GMO and free from added hormones.

Our take: Despite much effort over the years to explain all the features and benefits of organic products, there is still much to do. Thank you, OTA for articulating the opportunities we have to better inform and persuade shoppers about the ways organic products benefit them—and the planet.

Europeans Less Concerned About Sustainable Food

Concerns about sustainability of food products may be waning, according to a survey by EIT Food Consumer Observatory. Since 2020, the number of European consumers who consider sustainability when making food purchases dropped from 51% to 46%. Meanwhile, just 9% of Europeans prioritize sustainability in their lives. Reasons for the change include cost, with 31% mentioning budget as the main barrier to sustainable purchases, confusion over what is sustainable, and crisis fatigue.

Our take: Although this survey is of European consumers, we can relate to consumer confusion over what exactly is sustainable food, and the toll that bad news and coping with crisis can take. Perhaps it’s time to curl up with an organic beverage (latte, anyone?) and give ourselves a minute to relax.

By The Numbers—The Index

The annual overview of organic farmland, operators and markets “The World of Organic Agriculture,” from FiBL and IFOAM – Organics International, gives a glimpse of the €136.4 billion ($142.12 billion) market for organic products:

  • 198: countries with organic farming
  • 4.3 million: organic farmers
  • 99.9 million: hectares (246.86 million acres)
  • 2.5 million: increase in hectares (6.18 million acres)
  • €59 billion ($61.48 billion): Value of the largest market—the United States
  • 13%: Fastest market growth—Estonia
  • 53 million: Hectares (131 million acres) of organic farmland in Australia, top country by area

Certification News

Is It Ultra-Processed? New Seal Coming

The Non-GMO Project is working under the umbrella of the Food Integrity Collective to introduce certification for products that are not ultra-processed. The Non-UPF verification pilot project is expected to launch in the spring. The group describes ultra-processing as “typically involving breaking foods down into isolated components, then recombining them with industrial ingredients to create highly profitable products engineered to trigger cravings and override natural satiety signals.”

Our take: The devil is in the details. If you sell processed products, watch for opportunities to review and comment on this project as it evolves.

Expertise, Growth and Leadership for ACAs

Many of you know us (and love us!) for our work in certification, inspection prep, compliance support, and organic system plan (OSP) building with certified farms and handlers. More and more, we are serving accredited certifiers, helping with adverse action responses, mediation, process improvements, interim executive management, and strategic advice.

Wolf & Associates is the leading consultancy helping accredited certifying agents (ACAs) strengthen their operations, expand their reach, and enhance client partnerships. We understand the unique challenges certifiers face under the National Organic Program (NOP) and provide strategic guidance to navigate them effectively.

We tailor a team with the expertise and connections to help certification agencies grow and lead with confidence. Let’s start a conversation about how we can support your team.

Organic Community

Meet Our Team: Kelly Abbot

Kelly assists our clients with developing compliance strategies for maintaining organic certification, including preparing for inspections, record keeping, and managing non-compliance and adverse action resolutions, using over 25 years of experience in the organic and sustainable food. With experience in Director and Senior Management level positions, she has routinely engaged in certification processes, conducted inspections, and provided regulatory guidance for compliance with the National Organic Program (NOP).

Prior to joining Wolf & Associates, Kelly served as the Certification Program Director for a small organic certifier in Hawaii, successfully leading their accreditation during the initial NOP certification phase in 2005. She has participated in numerous on-site audits and has represented clients at National Organic Standards Board (NOSB) meetings, advocating for stronger livestock regulations.

Her career has spanned various positions across non-profit and for-profit organizations, including tenures with International Certification Service/Where Food Comes From and Oregon Tilth. She values continuing education to build on what she learned in her studies in sustainable agriculture.

Our Condolences

Phil Margolis, long time organic advocate and colleague, passed away January 25, 2025. A former president of the Organic Trade Association, Phil and his brother Gene founded Neshaminy Valley Natural Foods, a distributor with strict standards about product ingredients. Beyond his work in the organic sector, Phil was an attorney who advocated for young people as part of the Juvenile Law Center. May his memory bring joy to all who knew him.

Michael McGuffin, president of the American Herbal Products Association from 1999 until 2025, passed away February 17. A staunch advocate for a safe botanicals market, Michael advocated for good agricultural practices and safety guidelines for botanical products. His deep knowledge and dedication will be missed. Our condolences to all who knew and appreciated him.

Wolf & Associates Proudly Supports the Organic Trade Association’s
Educational Webinar Series

At Wolf & Associates, we are committed to strengthening the organic industry by supporting education, advocacy, and collaboration. That’s why we are proud to sponsor the Organic Trade Association (OTA) and their educational webinar series, designed to provide valuable insights and guidance on critical industry topics.

The first webinar in this series (March 17, 1 p.m. EDT) will focus on the NOSB Spring Meeting by  bringing together industry experts to share an in-depth review of the upcoming Spring 2025 NOSB meeting agenda.

For us, this sponsorship is more than just financial support—it’s an investment in the future of organic. By providing access to expert knowledge and fostering informed discussions, we help ensure that the organic community remains resilient, transparent, and forward-thinking.

We encourage you to join the upcoming webinar and take advantage of these valuable learning opportunities. Together, we can continue to build a strong, sustainable organic marketplace.

Save on Organicology 2025 Registration with Our Special Offer

Wolf & Associates has proudly supported the Organicology conference since 2009, and we’re excited to sponsor the 2025 edition, March 12-14, 2025 in Portland, Oregon. Organicology is more than just a gathering—it’s a powerful event that brings together advocates, contributors, and innovators from across the organic trade. Together, we work to revolutionize food, agriculture, and economic models to create a better, more sustainable future.

We would love for you to join us. As a valued part of our community, we’re offering an exclusive Wolf & Associates 30% discount on your registration fee. Use our custom code WOLF30 at checkout or follow this link to have the discount pre-loaded for you.

Our take: Attending Organicology offers so many benefits, from connecting with industry leaders to gaining insights into the latest organic trends and innovations. Wolf & Associates values this event for its commitment to pushing the organic industry forward, and we’re excited to share this opportunity with you.

Organic Trade Association Celebrates 40 Years of Advocacy

Congratulations on your anniversary, OTA! We’ve been there since the early days of the association, advocating for organic farmers (and earthworms) and working together to build an organic sector with integrity.

The anniversary video includes our CEO and Founder Bill Wolf (at 0:54), where he is advocating for organic in Washington, DC during one of the Association’s lobby days.

Our take: Working with elected officials is crucial for generating public policies that reflect the importance of the organic sector. If you haven’t done so yet, introduce yourself to your state and federal legislators, and tell them more about your business and why it matters to your community.