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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 and
October 2002                                                              Handling System Plan


Introduction
    In the earliest years of organic farming in the                In essence, organic certification is a simple
U.S., most of what was produced was consumed                   concept. A third party—an organic certifying
locally. In fact, freshness and direct marketing               agent—evaluates producers, processors, and
were often viewed as characteristics of organic                handlers to determine whether they conform to
production, along with the absence of chemi-                         an established set of operating guidelines
cal use. In those years, it was common                                    called organic standards. Those who
for the consumer to either have di-                                            conform are certified by the agent
rect 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 their
the 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 buyers
There was a greater like-                                                              of the organic product’s
lihood that organic prod-                                                              integrity.
ucts would pass through                                                                   By the late 1980s, there
many hands and travel                                                               were a number of private
many miles between the                                                             and state-run certifying bod-
farmer and the consumer. Un-                                                     ies operating in the United
der such circumstances, the end                                                States. Standards varied among
buyer needed some means to con-                                            these entities, causing problems in
firm 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 for
these needs through a process called third-party               processors trying to source ingredients. In ad-
certification.                                                 dition, a number of well-publicized incidents of


ATTRA is the national sustainable agriculture information service, operated by the National Center
for 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 and
organic 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 diverse
legislation. The result was the Organic Foods                             agroecosystem, which supports natural pest
Production Act of 1990, which mandated the cre-                           management. These techniques and materials
ation 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 organic
National 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 prohibited
www.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 conventional
ganic 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 and
2002.                                                                     pesticides; they also take precautions against
    The principal means by which the NOP is                               pesticide drift from off-farm and other sources
implementing the Regulations is through certi-                            of contamination. Many kinds of equipment and
fying agencies that it accredits. Through accredi-                        storage areas employed in organic production
tation, 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 organic
creditation also confirms that the certifier can                          use. A considerable amount of paperwork and
conduct 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” of
gram 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 not
certification. The basic steps and considerations                         have been used on the land for three full years
remain largely the same as in the past. These                             preceding harvest of the first organic crop. Farms
steps 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 and
this 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 their
livestock in ways that are not cruel and that take
account of the animals’ natural behavior. This
                                                        Information vs.
includes providing pasture for ruminants and
outdoor access for all livestock, and agreeing to       Consultation
restrictions 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 not
ducer are very basic. The five that follow are typi-    allowed. This new prohibition has created
cal, 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 MUST
agriculture 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 must
extension of the federal government, licensing
                                                        tell an applicant how and why he or she is out
producers 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 rectify
certifier should include:
                                                        the problem; that would be giving advice or
     • Their willingness and ability to answer
                                                        consultation. Similarly, the certifier can tell a
questions 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 available
ing judgment calls regarding compliance and it
                                                        information that provides advice and recom-
helps immensely if they understand the con-
                                                        mendations, such as Extension bulletins or
straints of your enterprise).
                                                        ATTRA publications, or suggest that clients
     • The certifier’s stability as a business (will
                                                        consult these sources; they may also provide
they 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 a
tifier be used).                                       copy of the certifier’s organic standards and an
     • Additional accreditation beyond the NOP         application packet, which typically includes an
by 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 certification
about 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 certification
materials one plans to use), and storage and han-          If certification is granted, the producer can
dling 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 that
tionnaire 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 have
to 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 the
certain that it is complete and that the operation     same federal standards, any clear violation of
appears 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 of
producer 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 given
the certifier assigns an organic inspector (7) to
                                                       when the certifier judges that the producer is
inspect all relevant areas of the farm. The in-
                                                       clearly unable to comply with federal organic
spector looks for all indications that the producer
                                                       regulations. For example, a farm that has had
is operating according to their organic plan and
                                                       chemicals used on it and is in its first or second
is in compliance with organic standards. He or
                                                       year of transition to organic production cannot
she inspects the fields, farm implements, and
                                                       be granted certification because the land must
buildings; reviews borders and adjoining land
                                                       be free from prohibited pesticides and fertilizers
use; 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,” or
seed sources, inputs used, compost production,
                                                       any similar terminology to describe and market
conventional production done on the farm, and
                                                       production from fields or farms in transition. This
records 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 with
the producer all identified non-compliance issues
at the end of the inspection. Finally, the inspec-     T he $5,000 Exemption
tor submits a detailed report to the certifier on
all findings. (Note that inspectors only record            Producers who market less than $5,000 worth
observations; they do not make decisions about         of organic products annually are not required to
certification.)                                        become certified, though they have the option of
     5) Final review The organic farm plan             doing so. These operations must still adhere to
application 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 they

PAGE 4                          //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
may label their products as organic, they may              Example 1       A state-based private certifier
not 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 are
Furthermore, 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 small
organic product. Retail stores may require ex-         farm in its first year of certification with gross
empted producers to sign an affidavit stating that     sales between $5,000 and $10,000 is $434. A larger
they 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-certification
Certification                                          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 calculated
Certifiers 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. In
ing bodies have had to undergo serious reorga-         most instances, this will make the total fees
nization to continue providing certification ser-      charged somewhat higher, because the travel
vices. 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 billed
costs would average approximately $750 per             if follow-up inspections are required. A $25 fee
farm. 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 with
of 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 certification
choosing 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 less
from five certifiers’ websites in late May 2002. The
                                                       than 101 acres; $175 for farms between 101 and
following 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 application
fee of $50 plus a farm inspection fee of $175. An         W ith Certification
additional fee of $100 is charged for inspection
of on-farm processing.                                    Costs
     In addition, assessment fees are charged on
a per-acre basis that varies by crop. Vegetable               The 2002 farm bill has set aside monies for a
and herb crops are assessed $25/acre; fruit and          national organic certification cost-share program
nut 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 $500
species. 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 Cost
ing 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 Organic
spection 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 sales
exceed $20,000. There is a cap of $20,000 on this
assessment.                                              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 is
Notes & References                                       reason to expect excessive contamination
                                                         with prohibited substances. Requests for
                                                         additional testing might be made at any
1)   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 via
3)   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 Resources
4)   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 Standards
5)   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 features
6)   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 Kuepper
NCAT Agriculture Specialist

Edited by Richard Earles
Formatted by Gail Hardy

October 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



          IP222




PAGE 8                        //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM

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Organic Farm Certification & the National Organic Program

  • 1. 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 and October 2002 Handling System Plan Introduction In the earliest years of organic farming in the In essence, organic certification is a simple U.S., most of what was produced was consumed concept. A third party—an organic certifying locally. In fact, freshness and direct marketing agent—evaluates producers, processors, and were often viewed as characteristics of organic handlers to determine whether they conform to production, along with the absence of chemi- an established set of operating guidelines cal use. In those years, it was common called organic standards. Those who for the consumer to either have di- conform are certified by the agent rect 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 their the 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 buyers There was a greater like- of the organic product’s lihood that organic prod- integrity. ucts would pass through By the late 1980s, there many hands and travel were a number of private many miles between the and state-run certifying bod- farmer and the consumer. Un- ies operating in the United der such circumstances, the end States. Standards varied among buyer needed some means to con- these entities, causing problems in firm 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 for these needs through a process called third-party processors trying to source ingredients. In ad- certification. dition, a number of well-publicized incidents of ATTRA is the national sustainable agriculture information service, operated by the National Center for 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.
  • 2. 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 and organic 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 diverse legislation. The result was the Organic Foods agroecosystem, which supports natural pest Production Act of 1990, which mandated the cre- management. These techniques and materials ation 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 organic National 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 prohibited www.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 conventional ganic 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 and 2002. pesticides; they also take precautions against The principal means by which the NOP is pesticide drift from off-farm and other sources implementing the Regulations is through certi- of contamination. Many kinds of equipment and fying agencies that it accredits. Through accredi- storage areas employed in organic production tation, 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 organic creditation also confirms that the certifier can use. A considerable amount of paperwork and conduct 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” of gram 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 not certification. The basic steps and considerations have been used on the land for three full years remain largely the same as in the past. These preceding harvest of the first organic crop. Farms steps are outlined in this publication. or specific fields that do not yet meet this require- PAGE 2 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
  • 3. ment may be considered as in transition, though A listing of accredited certifying agents and this 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 their livestock in ways that are not cruel and that take account of the animals’ natural behavior. This Information vs. includes providing pasture for ruminants and outdoor access for all livestock, and agreeing to Consultation restrictions 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 not ducer are very basic. The five that follow are typi- allowed. This new prohibition has created cal, 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 MUST agriculture 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 must extension of the federal government, licensing tell an applicant how and why he or she is out producers 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 rectify certifier should include: the problem; that would be giving advice or • Their willingness and ability to answer consultation. Similarly, the certifier can tell a questions 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 available ing judgment calls regarding compliance and it information that provides advice and recom- helps immensely if they understand the con- mendations, such as Extension bulletins or straints of your enterprise). ATTRA publications, or suggest that clients • The certifier’s stability as a business (will consult these sources; they may also provide they 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 a tifier be used). copy of the certifier’s organic standards and an • Additional accreditation beyond the NOP application packet, which typically includes an by 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
  • 4. 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 certification about 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 certification materials one plans to use), and storage and han- If certification is granted, the producer can dling 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 that tionnaire 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 have to 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 the certain that it is complete and that the operation same federal standards, any clear violation of appears 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 of producer 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 given the certifier assigns an organic inspector (7) to when the certifier judges that the producer is inspect all relevant areas of the farm. The in- clearly unable to comply with federal organic spector looks for all indications that the producer regulations. For example, a farm that has had is operating according to their organic plan and chemicals used on it and is in its first or second is in compliance with organic standards. He or year of transition to organic production cannot she inspects the fields, farm implements, and be granted certification because the land must buildings; reviews borders and adjoining land be free from prohibited pesticides and fertilizers use; 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,” or seed sources, inputs used, compost production, any similar terminology to describe and market conventional production done on the farm, and production from fields or farms in transition. This records 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 with the producer all identified non-compliance issues at the end of the inspection. Finally, the inspec- T he $5,000 Exemption tor submits a detailed report to the certifier on all findings. (Note that inspectors only record Producers who market less than $5,000 worth observations; they do not make decisions about of organic products annually are not required to certification.) become certified, though they have the option of 5) Final review The organic farm plan doing so. These operations must still adhere to application 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 they PAGE 4 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM
  • 5. may label their products as organic, they may Example 1 A state-based private certifier not 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 are Furthermore, 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 small organic product. Retail stores may require ex- farm in its first year of certification with gross empted producers to sign an affidavit stating that sales between $5,000 and $10,000 is $434. A larger they 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-certification Certification 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 calculated Certifiers 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. In ing bodies have had to undergo serious reorga- most instances, this will make the total fees nization to continue providing certification ser- charged somewhat higher, because the travel vices. 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 billed costs would average approximately $750 per if follow-up inspections are required. A $25 fee farm. 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 with of 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 certification choosing 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 less from five certifiers’ websites in late May 2002. The than 101 acres; $175 for farms between 101 and following 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
  • 6. Example 4 A state-based state-run certi- fier. Financial Assistance This state-run service charges an application fee of $50 plus a farm inspection fee of $175. An W ith Certification additional fee of $100 is charged for inspection of on-farm processing. Costs In addition, assessment fees are charged on a per-acre basis that varies by crop. Vegetable The 2002 farm bill has set aside monies for a and herb crops are assessed $25/acre; fruit and national organic certification cost-share program nut 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 $500 species. 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 Cost ing 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 Organic spection 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 sales exceed $20,000. There is a cap of $20,000 on this assessment. 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
  • 7. done. This is typically required if there is Notes & References reason to expect excessive contamination with prohibited substances. Requests for additional testing might be made at any 1) 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 via 3) 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 Resources 4) 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 Standards 5) 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 features 6) 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
  • 8. 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 Kuepper NCAT Agriculture Specialist Edited by Richard Earles Formatted by Gail Hardy October 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 IP222 PAGE 8 //ORGANIC FARM CERTIFICATION & THE NATIONAL ORGANIC PROGRAM