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

Inspectors up close | Packaging Matters | Livestock Regs on the Ropes

“Success isn’t about the end result, it’s about what you learn along the way.”  ~Vera Wang

SOE Update

Strengthening Organic Enforcement (SOE) is the biggest change in organic regulations in over 20 years. And full implementation is required in just over six months. Are your procedures and organic system plans updated and compliant? Are you prepared for the March 19, 2024 deadline? If not, now is the time to get going.

We’re at the halfway point to the required compliance deadline since the rule became final in March of this year. With barely six months to go, we do see progress, but not enough. USDA’s National Organic Program (NOP) is doing its part – communicating the changes, providing comparisons of the prior and new regulations, fact sheets, a new rule primer, webinars, and Q&A clarifications. NOP is being clear about the challenges and expectations for the sector.

Many other public and private agencies are also working on implementation. The import certificate platform (ACE) is targeted for a full-scale beta test in September. Providing foreign certifiers who operate under equivalency trade agreements with access to the platform to enter the import information mandated by the new rule is being established as well.

We at Wolf & Associates will continue doing presentations about SOE preparation through public webinars, presentations at trade events, and to our many clients who are requesting updates for their internal teams.

Challenges remain, including having enough qualified inspectors and reviewers to service the numerous handlers now required to be certified who had previously been exempt. Many certifiers are hiring to fill these gaps, which pre-existed SOE.

Two decades into having required federal standards, the industry has endured, often thrived, grown exponentially, and matured in unpredictable ways. Implementation of SOE will be another milestone, preceded by events such as the Alar Incident, the Harvey lawsuit, the Great Recession, and a global pandemic, and will no doubt be followed by events we can only guess about today.

We remain confident that the bumps and bruises the organic sector endures (sometimes self-inflicted!) make us stronger, help us mature and become more creative as we continue to challenge convention and bring better, more sustainable and climate-friendly food and fiber practices to the rest of the world. If you are not already on board, we resoundingly invite you to join us. We’re here to help you make a difference.
Bill Wolf
Bill Wolf

Featured Topic: Attracting and Keeping Organic Inspectors

For over 30 years, the International Organic Inspectors Association has been at the forefront of addressing issues and concerns relevant to organic inspectors, providing quality inspector training, and promoting consistency and integrity in the organic certification process. We recently chatted with IOIA’s Executive Director, Margaret Scoles, about some of the challenges in fostering a well-qualified pool of organic inspectors.

With the new Strengthening Organic Enforcement regulations coming up in March 2024, what are you doing to bolster the ranks of qualified organic inspectors?

Robust apprenticeship is the key to ensuring qualified inspectors—we can’t afford to have people learn on the job. Because lack of apprenticeships and mentors are two of the hurdles that people face, International Organic Inspectors Association is partnering with Accredited Certifiers Association to do a one-on-one mentorship pilot program this summer with National Organic Program funding. By the end of October, we’ll have a job task analysis on what it takes to be a mentor. Experienced inspectors often shy away from mentoring because they have not been paid; it’s time that work is acknowledged in a tangible way. The job task analysis will move us a step closer to accessing public funding to support formal apprenticeship.

IOIA was also very involved in five of the projects the NOP funded to build human capital. We developed an intensive apprenticeship model, created a recruitment video that is now in the Organic Integrity Learning Center, and generated materials about organic inspection for career advisors.

What could others in the supply chain (farmers, processors, importers, exporters, distributors, etc.) do to help ensure there are enough well qualified organic inspectors available to handle the increasing workload?

Industry has stepped up to sponsor training. As one example, Organic Valley’s Farmers Advocating for Organic grant program sponsored intensive apprenticeship training for livestock inspectors. We’d love to see more of that.

We need to do more recruitment and more advertising of what we do. Most of the people who became inspectors learned about the career from friends and family who were inspectors. We need to make our case better for why this is a good career.  Sharing the Become An Organic Inspector video that IOIA created with Oregon Tilth as part of the NOP’s efforts to build human capital would help.

What else is important for the organic community to understand about the challenges of attracting, training and retaining organic inspectors in the age of SOE?

What we need is experience, and we’re not doing well enough at retaining that experience. It’s important to recognize the value of a good inspection and the risk if we don’t retain experience. The cost of a bad inspection is harm to the reputation of all organic products. Professional credentialing is currently lacking and IOIA believes it could also help improve quality and retain experience.

Margaret ScolesMargaret Scoles serves as Executive Director of the International Organic Inspectors Association, maintaining the IOIA office in Montana since 1999. She has over 30 years of organic inspection experience, including inspection of farms, livestock, and processors and has been training organic inspectors since 1989. A founding board member of IOIA (1991-1992), she is a respected leader in the organic community. Margaret currently serves as a board member and treasurer for IFOAM North America.

Organic Regulatory Updates


More New Organic Integrity Learning Center Courses

  • Especially for handlers and processors, “Keep It Organic When Handling and Processing” is one of the newest courses on the National Organic Program’s Organic Integrity Learning Center.The course introduces elements of certification, including types of handling processes, product labeling categories and composition requirements, facility pest management, sanitation, commingling risks and prevention.
  •  “Livestock Traceability” focuses on the role of livestock traceability within the USDA organic control system and introduces ways to strengthen organic integrity and identify potential fraud.

Organic Integrity Learning Center courses are free and open to all.

Strengthening Organic Enforcement Deadline Countdown
March 19, 2024 is the compliance date for the Strengthening Organic Enforcement regulations. That’s just 216 days, or 30 weeks and 6 days, away. There’s no time to lose, especially as certifiers are likely to get busier as the deadline approaches. If you or your supply chain partners have need for additional support in getting ready, let us know.

Fall NOSB Meeting Agenda and Public Comment
Keep an eye open for the announcement for the Fall National Organic Standards Board Agenda and opportunity to sign up for public comment. Typically, these are announced about two months prior to the meeting date, so expect it toward the end of August. Remember that the limited number of 3-minute speaking slots go quickly! Information about the meeting in Providence, Rhode Island in late October can be found here.

Inside the Beltway

Organic Livestock Welfare Regulations at Risk
In a move that would effectively block the adoption of the Organic Livestock and Poultry Standards (OLPS), Congressman Keith Self (R-Texas) offered an amendment to the House Agriculture Appropriations bill to prohibit agriculture appropriation funds from being used to write, prepare, or publish, implement, or enforce the proposed rule. The Organic Trade Association (OTA) is urging Congress to oppose Self’s amendment to stop the advancement of organic animal welfare regulations, calling the effort unjust and unwarranted and part of a broader attempt to dismantle the National Organic Program. The OLPS regulations have been under discussion and review for over twenty years and are widely supported by the organic sector and the public at large. Wolf & Associates has signed on to the Organic Trade Association’s industry letter and has requested that our federal legislators oppose the Self amendment.

International News

European Union Report Examines Organic Imports
Using charts and graphs, “EU imports of organic agri-food products” looks at changes in organic imports from 2021 to 2022, including product types, importing countries and volume of products. Overall, the volume of organic imported agricultural products fell 5.1% thanks to reduced imports of fruit and vegetables, sugar, olive and palm oils, sunflower seed and pet food. Increases in soybeans, oilcake, citrus fruit, rice, and honey were not enough to balance the decline. About 98% of organic imports are commodities and primary products. Olive oil remains the imported organic product with the largest market share compared to imports of non-organic olive oil, with about 21% of imported olive oil as organic.

The Survey Says…

New Survey Sheds Light on Compostable Packaging
A new survey from the Composting Consortium and the Biodegradable Products Institute found consumers are more likely to correctly identify compostable packaging if it uses multiple design elements to indicate its compostability. In addition, color especially natural base materials, brown or green coloring or green tint, increased survey participants’ ability to identify the packaging as compostable. Correct disposal of compostable packaging can be a challenge, since only 7% of the respondents have access to curbside collection for compostable materials that include packaging.

Consumers are also confused about how to dispose of compostable packaging at home. Of those who compost at home, 1/3 would put compostable packaging in the home compost even though the packaging is designed for commercial composting facilities.

Furthermore, 40% of consumers incorrectly believe that biodegradable equals compostable. The report, “Unpacking Labeling and Design: U.S. Consumer Perception of Compostable Packaging” includes public policy suggestions to foster sustainability.

The Dirt on What Lives in Soil
Soil is the most diverse and species-rich habitat on Earth, according to a paper published in the Proceedings of the National Academy of Sciences, and is home to an approximately 90% of fungi, 85% of plants and over 50% of bacteria species. Researchers estimate that soil is home to 59% of life. About 1/3 of the planet’s soil is severely degraded, and 24 billion tonnes of fertile soil are lost every year due to erosion.

Culinary and Nutrition Interests Outpace Interest in Sustainability
In a survey of people who regularly interact with food/beverage related online content and dine out often, the marketing firm Curious Plot’s Consumer Curiosity Report found a lower than anticipated interest in sustainability topics.  Although culinary and nutrition topics ranked higher than sustainability topics, within the sustainability category 47% of respondents expressed interest in reducing food waste. The other top sustainability interests were animal welfare and organic agriculture. Only 22% were “extremely curious” about climate friendly eating.

Survey to Assess If Packaging Will Comply with EU Requirements
Due to proposed changes in Europe’s requirements for food packaging that emphasize environmental sustainability, increased reuse and recycling, and more, a project on identifying packaging barriers for exporting specialty crops is underway at Michigan State University. Conducted in conjunction with the United States Department of Agriculture’s Foreign Agriculture Service, the project will assess the packaging used for specialty crops (almonds, pistachios, pecans, walnuts, hazelnuts, sweet potatoes, asparagus, onion, mushroom, grapefruit, tangerine, mango, cranberry, peppers, cherries, oranges, blueberries, strawberries, apples, and carrots) to identify the likelihood the packaging will comply with European Union regulations. Researchers are looking for stakeholders willing to share information about their packaging systems for exported specialty crops. Stakeholders will receive the results of the assessments. For more information contact: Dr. Rafael Auras at or Carinna Saldaña, Participants can complete the survey online.

GMO News

Mexico Proposes Banning GMO Corn From Masa Products
Mexico’s Health Ministry published a draft proposal in early July that would ban the use of genetically modified corn in products, including tortillas, made from masa. On July 28, 2023, the World Trade Organization opened a 60-day comment period on Mexico’s revision of its Official Standard to ban the use of genetically modified corn in the nixtamalization process. The change would apply to domestic and imported products. This comes after Mexico imposed a 50% tariff on white corn imports, as an effort to limit human consumption of GMO corn and to boost domestic white corn production. Meanwhile, the United States initiated formal trade dispute resolution proceedings over Mexico’s efforts to ban GMO corn. More.

Japan studies GMO seeds spilled along roadways during transit
In the latest survey of 79 colonies of fewer than 100 genetically modified plants in total, Japan’s Ministry of Agriculture, Forestry and Fisheries (MAFF) did not find any evidence that the rapeseed and soy plants pose a risk to the surrounding biodiversity, reports Food Navigator-Asia. Since 2006 MAFF, has been been monitoring roadside GMO rapeseed and GMO soy plants believed to have originated from seeds spilled during transportation. MAFF did not find significant crossing between GM plants and local plants and has not seen the growing range of the GM plants expand. Cultivation of GMO plants is not permitted in Japan, but imported GMO products are allowed. More.

Organic Industry News & Notices

Learn About Inputs From OMRI and IOIA
The Organic Materials Review Institute and the International Organic Inspectors Association will offer a series of online courses for inspectors, consultants and reviewers on National Organic Program-based input materials:
  • October 11: 100 Level NOP Processing Input Materials
  • November 15: 200 Level NOP Processing Input Materials
  • December 13: 100 Level NOP Crop Input Materials
These trainings meet new requirements for continuing education in the Strengthening Organic Enforcement (SOE) Final Rule. Register well in advance, as course requirements begin before the classes meet and seating is limited to 20 per class.

Pet Food Labeling Gets an Upgrade
In its first major update in more than 40 years, pet food labeling guidelines approved by the Association of American Feed Control Officials (AAFCO) will include standardized nutrition information, clear ingredient statements, and storage and handling instructions. AAFCO recommends a transition period of six years for manufacturers to fully incorporate the label and packaging changes to their products.

Organic Community

CCOF to Celebrate Golden Anniversary
Congratulations to California Certified Organic Farmers on 50 years of encouraging organic agriculture. The organization will celebrate its roots September 15 at Sonoma Hills Farm with a farm tour, dinner and music.

OMRI Welcomes New Board Member
Silvia Abel-Caines, Ph.D., of Organic Valley, is the newest member of the Organic Materials Review Institute’s Board of Directors. A veterinarian with expertise in ruminant nutrition, Silvia not only works for Organic Valley, she also owns a certified-organic farm and seeks to increase urban and rural community access to nutrient-dense food. Congratulations!