USDA Organic: Production, Handling and Certification

Organic handling extends beyond physical processing. Selling, trading, facilitating transactions, importing and exporting can bring an operation within the certification framework. USDA identifies limited exemptions, but an exempt operation can still have applicable handling and recordkeeping responsibilities. Determine what each participant actually does instead of assuming a sealed package removes every obligation. USDA certification coverage.

The applicable production and handling requirements are documented through the organic system plan and supporting practices. Crop, livestock and processed-product operations have different control subjects. Prevention of commingling and contact with prohibited substances matters through storage and handling. A supplier’s certificate does not by itself describe the controls needed at a subsequent operation. Part 205.

Organic labeling categories have different composition and presentation requirements. The National List and other provisions address substances permitted or prohibited in specified circumstances. A material is not universally allowed because it appears somewhere on the list. Check its category, use restrictions and the product’s labeling claim before incorporating it into an organic system. USDA organic regulation.

Certification is performed by an appropriate certifying agent for the operation’s activities. USDA’s current coverage explanation emphasizes that most organic-trade entities require certification. Recordkeeping connects purchases, handling and sales so organic status can be traced. An operation certificate and an import certificate serve different purposes and should not be substituted for one another. USDA certification explanation.

Strengthening Organic Enforcement entered full compliance on March 19, 2024. Applicable organic shipments require an NOP Import Certificate issued through the official system by the exporting certifier, with import data transmitted into the entry process. Specific limited exceptions require separate analysis. An ordinary commercial certificate of analysis does not establish organic import eligibility. USDA SOE questions.

Identify each operation and its certification position, check formula and handling controls, and verify the product’s labeling category. For imports, reconcile the shipment, certificate and importer information before movement. USDA’s current FAQ also describes restrictions on reconditioning shipments arriving without a valid import certificate; historical grace practices should not be presumed available. Current implementation questions.