NOP Import Certificate requirements for US organic sales grace period ends September 19, 2024. Are you ready? Click here.
Wolf & Associates Organic Faqs


You have questions. We have answers.

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. Organic growers, manufacturers, ingredient suppliers, retailers and handlers must be certified by an “Accredited Certifying Agent” (independent third-party) that has been approved and audited by the USDA.

Organic and its derivations can be used only on certified organic products and ingredients. Organic labeling depends on the product composition:
  • 100% Organic―If a raw or processed agricultural product contains all organically produced ingredients, it may carry both the USDA Organic seal and a 100% Organic claim.
  • Organic―If a raw or processed agricultural product is made with at least 95% organically produced ingredients, and all remaining ingredients (and the remaining 5% meet specific criteria), it may carry the USDA Organic seal with an Organic claim.
  • Made With Organic―If a multi-ingredient agricultural product contains at least 70% organic ingredients (and the remaining 30% meet specific criteria), the label may list up to three organic ingredients or food groups.
  • Less than 70% Organic―If the product contains less than 70% organic ingredients, you may only identify the organic content of the product in the ingredient statement and information panel.
“Transition to Organic” claims are not allowed. For more detailed information on labeling, Contact Wolf & Associates.

Agricultural products, whether raw or processed, are eligible for organic certification if they are produced according to the standards set forth by the NOP. Generally, this means fruits, vegetables and grains may be certified organic, as well as processed foods made with these crops (e.g., pastas, sauces, beverages, snacks, etc.).

Finished textiles do not qualify for organic certification, however, raw fibers such as cotton and flax do qualify.

Materials that are used in the production of organic crops, livestock and processed foods – such as fertilizers, sanitizers or nonagricultural processing aids – generally are not eligible for organic certification. However, they still must comply with NOP standards in order to be allowed for use in organic production. Often, these materials are assessed by Material Review Organizations (MROs) such as OMRI to ensure NOP-compliance.

Contact Wolf & Associates to help you determine if your specific product qualifies for organic certification or MRO listing.

The answer is yes and no. Here’s why:

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 may qualify for a private standard.

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 Contact Wolf & Associates.

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. Contact Wolf & Associates 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.

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 .

Contact Wolf & Associates for advice on effective petitioning, trends, timing, potential barriers, likely opinions of organic stakeholders, and the nuances of successful petitions.

Many companies and organizations today are interested in implementing and promoting sustainable practices throughout their operations. At this time, there are a handful of different programs against which you can benchmark your environmental, social, and economic performance. Contact Wolf & Associates about the options and to facilitate a strategic discussion on the pros and cons of each, given your specific business objectives.
The short answer is yes. Requirements vary by country. For an overview, see this NOP fact sheet: Exporting Organic Products from the U.S. 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, Contact Wolf & Associates. 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 so you can plan accordingly.