Organic Farm Certification & the National Organic Program MARKETING TECHNICAL NOTE Abstract: Farmers planning to market their products as “organic” must become certified. This guide outlines the considerations involved in “going organic” and the basic steps to organic certification. The sole exemption to mandatory certification is also discussed.By George Kuepper Related ATTRA Publications:NCAT Agriculture Specialist • Overview of Organic Crop Production • Creating An Organic Production andOctober 2002 Handling System PlanIntroduction In the earliest years of organic farming in the In essence, organic certification is a simpleU.S., most of what was produced was consumed concept. A third party—an organic certifyinglocally. In fact, freshness and direct marketing agent—evaluates producers, processors, andwere often viewed as characteristics of organic handlers to determine whether they conform toproduction, along with the absence of chemi- an established set of operating guidelinescal use. In those years, it was common called organic standards. Those whofor the consumer to either have di- conform are certified by the agentrect contact with the grower, or and allowed to use a logo,have confidence in a retailer product statement, or certifi-who purchased directly from cate to document theirthe grower. However, as product as certified organic.the organic market began In other words, the certi-to expand in the 1970s, the fier vouches for the pro-supply chain lengthened. ducer and assures buyersThere was a greater like- of the organic product’slihood that organic prod- integrity.ucts would pass through By the late 1980s, theremany hands and travel were a number of privatemany miles between the and state-run certifying bod-farmer and the consumer. Un- ies operating in the Unitedder such circumstances, the end States. Standards varied amongbuyer needed some means to con- these entities, causing problems infirm that the purchased product was truly commerce. Certifiers often refused to rec-organic. Likewise, the farmer needed a way of ognize products certified by another agent as or-proving to the consumers that he or she used or- ganic, which was a particular problem for or-ganic methods. The organic industry addressed ganic livestock producers seeking feed, and forthese needs through a process called third-party processors trying to source ingredients. In ad-certification. dition, a number of well-publicized incidents ofATTRA is the national sustainable agriculture information service, operated by the National Centerfor Appropriate Technology through a grant from the Rural Business-Cooperative Service, U.S.Department of Agriculture. These organizations do not recommend or endorse products,companies, or individuals. NCAT has offices in Fayetteville, Arkansas (P.O. Box 3657, Fayetteville,AR 72702), Butte, Montana, and Davis, California.
Table of Contents Considering Organic Introduction ................................................... 1 Certification Considering Organic Certification ............... 2 Steps To Organic Certification ..................... 3 Motivations Organic farming is an envi- Information vs. Consultation ........................ 3 ronmentally responsible approach to producing high-quality food and fiber. Personal health and The $5,000 Exemption ................................... 4 environmental concerns have long been motivat- Fees for Organic Certification ...................... 5 ing factors for those who choose to farm organi- cally. Increasingly, however, economics has be- Financial Assistance With Certification come a major factor. Organic farmers typically Costs ........................................................ 6 earn a premium for their production, and though it is not true for all products, many organic com- Summary ........................................................ 6 modity crops have lower costs of production than Notes & References ....................................... 7 the same conventional crops. Commitments Farming organically in- Further Resources ......................................... 7 volves committing to two principles: ecological production and maintaining organic integrity. Eco- logical production entails using farming and ranch-fraud began to undermine the credibility of the ing techniques and materials that conserve andorganic industry. In an effort to curb these prob- build the soil resource, pollute little, and encour-lems, the organic community pursued federal age development of a healthy diverselegislation. The result was the Organic Foods agroecosystem, which supports natural pestProduction Act of 1990, which mandated the cre- management. These techniques and materialsation of the National Organic Program (NOP) include diverse crop rotations, green-manuring,and the passage of uniform organic standards. cover crops, livestock manure, composting, min-These standards are now incorporated in the eral-rich rock powders, etc. Maintaining organicNational Organic Program Regulations, which integrity consists of actions that prevent contami-can be found on the NOP Website at <http:// nation of organic production with prohibitedwww.ams.usda. gov/nop/>. Implementation of materials, and that prevent the accidental mix-the Regulations began on April 21, 2001; all or- ing (commingling) of organic and conventionalganic certifiers, producers, processors, and han- products. Farmers accomplish this, first of all,dlers must be in full compliance by October 21, by not using prohibited synthetic fertilizers and2002. pesticides; they also take precautions against The principal means by which the NOP is pesticide drift from off-farm and other sourcesimplementing the Regulations is through certi- of contamination. Many kinds of equipment andfying agencies that it accredits. Through accredi- storage areas employed in organic productiontation, the NOP assures that the certifier under- must either be dedicated to organic use or prop-stands and is using the National Standard; ac- erly cleaned between conventional and organiccreditation also confirms that the certifier can use. A considerable amount of paperwork andconduct the business of certification properly. documentation is required to ensure organic in- Implementation of the National Organic Pro- tegrity; it is one of the necessary “burdens” ofgram Regulations will lead to a number of being a certified organic farmer or rancher.changes in how producers, handlers, processors Prospective organic producers should under-and others do their jobs. One thing that will not stand in advance that prohibited substances (syn-change greatly, however, is the process of farm thetic fertilizers and pesticides, etc.) must notcertification. The basic steps and considerations have been used on the land for three full yearsremain largely the same as in the past. These preceding harvest of the first organic crop. Farmssteps are outlined in this publication. or specific fields that do not yet meet this require-PAGE 2 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
ment may be considered as in transition, though A listing of accredited certifying agents andthis term does not have legal status at this time. those making application for accreditation is cur- Organic livestock producers must make a fur- rently featured on the NOP website.ther commitment—to manage and raise theirlivestock in ways that are not cruel and that takeaccount of the animals’ natural behavior. This Information vs.includes providing pasture for ruminants andoutdoor access for all livestock, and agreeing to Consultationrestrictions on physical alterations. Prior to the implementation of national or- ganic standards, producers commonly sought Steps To Organic the advice of certifying agents and organic inspectors on matters ranging from pest con- Certification trol strategies and livestock treatments, to crop rotation schemes and the best sources of purchased inputs. Such advice is now The steps to becoming a certified organic pro- considered a conflict of interest and is notducer are very basic. The five that follow are typi- allowed. This new prohibition has createdcal, though variations might apply in different considerable confusion in the organic com-circumstances. munity. 1) Identify a suitable certifier Organic The key to sorting out this problem is rec- ognizing the basic difference between infor-certification agencies may be operated by a state mation and consultation. Certifiers MUSTagriculture department, or they may be private make essential information about their certi-entities, but they must be accredited by the Na- fication process, their fees, and similar mat-tional Organic Program. Certifiers work as an ters available to the public. The certifier mustextension of the federal government, licensing tell an applicant how and why he or she is outproducers to use the term “organic” in selling of compliance. However, the certifier CAN-their products. Criteria to use in evaluating a NOT advise the applicant on how to rectifycertifier should include: the problem; that would be giving advice or • Their willingness and ability to answer consultation. Similarly, the certifier can tell aquestions about their certification program. producer whether or not a particular pest con- • Membership in prominent and valuable trol product is permitted for use. However,organizations such as OTA (1) and OMRI (2). the certifier may NOT advise about how to • Their history in certifying your kind of use the product or where to buy it.enterprise (Certifiers are in the position of mak- Certifiers may distribute publicly availableing judgment calls regarding compliance and it information that provides advice and recom-helps immensely if they understand the con- mendations, such as Extension bulletins orstraints of your enterprise). ATTRA publications, or suggest that clients • The certifier’s stability as a business (will consult these sources; they may also providethey be operating again next year?). producers with lists of private consultants, but • Additional certification services they of- may NOT recommend a specific one.fer (e.g., Kosher, Free Farmed (3), etc.). • Market recognition of the certifier logo. • The needs of buyers (the buyer of an or- 2) Submit an application After identi-ganic commodity may request that a specific cer- fying a certifier, the producer should request atifier be used). copy of the certifier’s organic standards and an • Additional accreditation beyond the NOP application packet, which typically includes anby international certification bodies such as organic farm plan questionnaire (5). An appli-IFOAM (4). cation fee is commonly requested at this stage. • Costs of certification. The producer should read the standards and ma- //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM PAGE 3
terials lists carefully; the certification agent can dards. There can be several outcomes of the re-answer any questions. The producer must com- view:plete the questionnaire, which elicits information • Approval for organic certificationabout the farm or ranch, including details about • Request for additional information (6)soil fertility planning, seeds and seedlings, weed • Notification of noncompliance (8)and pest management practices (including the • Denial of certificationmaterials one plans to use), and storage and han- If certification is granted, the producer candling routines. Farm maps will be required along begin marketing his or her products as organic.with crop and input histories for all fields. Strat- The producer is free to use the seal of the certi-egies to prevent contamination with prohibited fier and also the USDA’s organic seal (after Oc-substances and commingling with non-organic tober 21, 2002).products must be outlined. The farm plan ques- Notification of noncompliance implies thattionnaire will also elicit information on the the applicant will be granted certification if cer-producer’s plans to monitor the farm operation tain things are changed. A producer does haveto insure compliance. The producer may sign a the option of rebutting a charge of noncompli-licensing agreement with the certifier at this time. ance. He or she also has the option of making 3) Completeness review The certifier application through another certification agent.reviews the organic farm plan application to be However, since all certifiers must recognize thecertain that it is complete and that the operation same federal standards, any clear violation ofappears able to comply with NOP organic stan- standards will need to be rectified. Noncompli-dards. If additional information is required, the ance issues often involve inadequate records ofproducer will be asked to submit it. (6) such things as manure applications, equipment cleaning on farms where conventional produc- 4) On-farm inspection If the organic tion is also done, and compost preparation.farm plan application is judged to be complete, A denial of certification is typically giventhe certifier assigns an organic inspector (7) to when the certifier judges that the producer isinspect all relevant areas of the farm. The in- clearly unable to comply with federal organicspector looks for all indications that the producer regulations. For example, a farm that has hadis operating according to their organic plan and chemicals used on it and is in its first or secondis in compliance with organic standards. He or year of transition to organic production cannotshe inspects the fields, farm implements, and be granted certification because the land mustbuildings; reviews borders and adjoining land be free from prohibited pesticides and fertilizersuse; and assesses contamination and commin- for a minimum of three years.gling risks. The inspector reviews all written At this time, producers may not use “or-records documenting management practices, ganic,” “transitional,” “transition to organic,” orseed sources, inputs used, compost production, any similar terminology to describe and marketconventional production done on the farm, and production from fields or farms in transition. Thisrecords of harvest, storage, transportation, and issue is under consideration by the National Or-sales. An inspection affidavit is completed dur- ganic Program and some legal form of transi-ing the inspection and signed by the producer tional status may be recognized in the future.and the inspector. The inspector reviews withthe producer all identified non-compliance issuesat the end of the inspection. Finally, the inspec- T he $5,000 Exemptiontor submits a detailed report to the certifier onall findings. (Note that inspectors only record Producers who market less than $5,000 worthobservations; they do not make decisions about of organic products annually are not required tocertification.) become certified, though they have the option of 5) Final review The organic farm plan doing so. These operations must still adhere toapplication and inspection report is reviewed by the federal standards for organic production,an individual or certification committee with ex- product labeling, and handling. Exempted op-pertise in organic farming and certification stan- erations face two other constraints. While theyPAGE 4 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
may label their products as organic, they may Example 1 A state-based private certifiernot use the USDA seal, the seal of a certifier, or that also provides services on the national level.otherwise claim that their production is certified. Within-state fees: The basic producer fees areFurthermore, they may not sell their products as on a sliding scale based on the gross farm sales.ingredients for use in someone else’s certified For example, the basic certification fee for a smallorganic product. Retail stores may require ex- farm in its first year of certification with grossempted producers to sign an affidavit stating that sales between $5,000 and $10,000 is $434. A largerthey adhere to federal organic standards. operation with sales between $100,000 and $125,000 would be charged a fee of $1,112. A farm selling over $500,000 worth of organic pro-Fees for Organic duction would be charged $2,517 plus 0.1% of total sales in excess of $500,000. Re-certificationCertification in subsequent years costs about $155 less for any operation, regardless of size. Certification costs can be expected to rise. Out-of-state fees: These fees are calculatedCertifiers must now bear the added costs of similarly to the ones charged within state. How-USDA accreditation. In some instances, certify- ever, inspection costs are billed separately. Ining bodies have had to undergo serious reorga- most instances, this will make the total feesnization to continue providing certification ser- charged somewhat higher, because the travelvices. These costs will be passed on to produc- costs of an inspector are usually greater.ers and handlers in the form of higher fees. Note that for both within-state and out-of- The NOP initially estimated that certification state applicants, additional charges will be billedcosts would average approximately $750 per if follow-up inspections are required. A $25 feefarm. However, fees charged for certification will be charged if application forms are incom-vary among agents. Fees also vary with the size plete and must be re-submitted.and complexity of the farm operation, the costs Example 2 A national private certifier withof inspection, and other factors. Be certain to get strong regional focus.a clear explanation of the fee structure when This certifier charges $25 for the certificationchoosing a certifier. packet and $50 for a first-time application. We obtained a sampling of fee information The base certification fee is $150 for farms lessfrom five certifiers’ websites in late May 2002. The than 101 acres; $175 for farms between 101 andfollowing examples were generated from that sam- 500 acres; $225 for farms larger than 500 acres.pling to give a notion of the range of fees and the An additional $50 is charged if livestock certifi-different ways in which they are calculated. cation is desired. This does not include the costs of inspection, which can vary consid- erably beginning at a low of approximately $175. There is also a 0.5% assessment on gross sales, with an annual cap of $5,000. Further fees are assessed for certification of on-farm processing. Example 3 A state-based private cer- tifier. Among the smaller certifying bodies at this time, this agent charges an up-front fee of $350 for initial document review and on-site inspection. Additional inspec- tion and laboratory fees may be charged as required. //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM PAGE 5
Example 4 A state-based state-run certi-fier. Financial Assistance This state-run service charges an applicationfee of $50 plus a farm inspection fee of $175. An W ith Certificationadditional fee of $100 is charged for inspectionof on-farm processing. Costs In addition, assessment fees are charged ona per-acre basis that varies by crop. Vegetable The 2002 farm bill has set aside monies for aand herb crops are assessed $25/acre; fruit and national organic certification cost-share programnut crops are assessed $15/acre; corn is assessed to help producers and handlers of organic prod-$2.50/acre; soybeans are assessed $4.00/acre. ucts obtain certification. The bill allows a maxi- Organic livestock are assessed on a per-head mum federal cost share of 75% of the cost of cer-basis for large stock and per-100-head for smaller tification, with a maximum payment of $500species. The assessments include $10/head for made to a producer or handler under this provi-cattle, $1/head for sheep or goats, $1/100 head sion.for slaughter chickens, and $10/100 head for lay- The National Organic Certification Costing hens. Share Program is funded at $5 million over the 6-year life of the farm bill. This is in addition to $1 million that had already been made available Example 5 A state-based private certifier. through the crop insurance bill for the Northeast- This certifier charges an initial application fee ern states.of $250 plus the costs of inspection (which can It is anticipated that this money will be ad-vary widely) plus a 25% service charge. Renewal ministered through the National Organic Pro-fees for most producers are $165 (farms with sales gram. Producers should contact their state or-less than $20,000 pay $110) plus the costs of in- ganic program offices or the National Organicspection and the service charge. Program for details on how to apply for this as- In addition to these fees, there is an annual sistance.assessment fee of 0.5% on gross organic and tran-sitional product sales for producers whose salesexceed $20,000. There is a cap of $20,000 on thisassessment. Summary Federal standards for organic production and marketing have not significantly changed the process of organic certification. Producers will continue to be certified through private and state- run certification agencies. Certification services vary widely and producers are encouraged to “shop around” before selecting an agent. Farmers selling less than $5,000 of organic products annually may opt out of certification. However, they must still comply with the requirements of the National Organic Program Regula- tions. Certification costs are expected to rise, though the actual cost and how it is calculated can vary widely. Federal assistance with certification costs will soon be available.PAGE 6 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
done. This is typically required if there isNotes & References reason to expect excessive contamination with prohibited substances. Requests for additional testing might be made at any1) OTA (the Organic Trade Association) is a point in the application process or later. membership-based business association representing the organic industry in 7) Organic inspectors may be employees of Canada, the U. S., and Mexico. It works the certifier, but many are independent to promote organic products in the mar- contractors. Many inspectors are mem- ketplace and to protect the integrity of bers of, and receive training from, the organic standards. For more information, Independent Organic Inspectors Associa- visit their Website at <http:// tion (IOIA). For more information on www.ota.com/>. IOIA, visit their Website at <http:// www.ioia.net/>.2) OMRI (the Organic Materials Review Institute) evaluates materials for use in 8) According to John Foster (Quality Assur- most aspects of organic production, ance International), farmers with minor handling, and processing. Their pub- noncompliances might be granted certifi- lished guides of approved inputs are cation with the understanding that these invaluable for informing clients as to violations be corrected within a specified what they may and may not use in their time period. Where major operations. For more information on noncompliances occur, certification is OMRI, visit their Website at <http:// likely to be withheld until the applicant www.omri.org/>. has made and documented the required changes. (Information provided via3) Like Organic, Free Farmed is another personal communication, March 2002.) example of eco-labeling. For more infor- mation on the Free Farmed label, visit the Farm Animal Services Website at <http:/ /www.freefarmed.org/>. Further Resources4) IFOAM is the International Federation of Organic Agriculture Movements. Their The National Organic Program Website at accreditation program for organic certifi- <http://www.ams.usda.gov/nop/> has been cation agencies is operated by the Interna- cited several times throughout this publication. tional Organic Accreditation Service (IOAS). It is important to note the wealth of additional For more information on IOAS and information that can be found there, including IFOAM, visit their Website at <http:// background information on the legislation, an www.ifoam.org/>. FAQ (Frequently Asked Questions) page, and guidance from the National Organic Standards5) For more information on the organic farm Board (NOSB)—an advisory body to the NOP plan requirement, please request a copy of that assists in interpreting the Regulations and the ATTRA publication Creating An makes recommendations on materials and prac- Organic Production and Handling System tices that can and cannot be used in organic pro- Plan. This publication includes template duction. forms in common use by certification agencies. The Organic Trade Association Website features6) The kinds of additional information a a summary legislation page at <http:// certification agent might seek are various. www.ota.com/legislat.htm>, which gives an In some instances the agent may require excellent overview of the history of federal regu- that additional testing of soils, water, lation plus many details contained in the Regu- compost, crops, feeds, or other items be lations. //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM PAGE 7
The National Campaign for Sustainable Agricul-ture closely monitors federal legislation regard-ing organic farming. Visit their website at<http://www.sustainableagriculture.net/index.htm>. Acknowledgements: Special thanks to Diane Bowen (IFOAM), John Foster (QAI), Harriet Behar (IOIA), and Joyce Ford (Organic Independents) for re- viewing and providing comments on this pub- lication.By George KuepperNCAT Agriculture SpecialistEdited by Richard EarlesFormatted by Gail HardyOctober 2002 The electronic version of Organic Farm Certification & the National Organic Program is located at: HTML http://www.attra.ncat.org/attra-pub/organcert.html PDF http://www.attra.ncat.org/attra-pub/PDF/organcert.pdf IP222PAGE 8 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM