Chapter 2

Organic Crop Certification

The Organic Certification Process

Certification under the National Organic Program (NOP) is required to label, represent, and market qualifying products as organic. There are two categories of organic operations: producers and handlers. Organic producers may grow crops or collect plants from the wild. These farming operations receive an organic producer certificate. Organic handlers may buy food for resale or may process foods (slicing, freezing, drying, mixing, blending, etc.). These operations receive an organic handler certificate. The organic certificate verifies that the producer or handler has complied with organic regulations and allows their operation to sell or represent the product as organic. Producer certificates include the type of crop (e.g., carrots, apples) and may include other information as well. Sometimes crop varieties are listed (Fuji apples), as well as farm acreage and the name of the field from which the crop has been harvested.

Producer Submits an Application to a Certifying Agent

Producers obtain certification from state or private certifiers who are accredited by the NOP. Farmers may apply to any accredited certification agent. To allow time for the entire certification process, submit your application at least three to six months before the harvest of your first organic crop. If you need a certificate more quickly, some certifiers will expedite your application for an additional fee. The documents sent to a certifier are often collectively called the “application,” but in reality, there are several separate documents required:

Application

An operation that wants to become certified first contacts a certifying agent. The certifying agent provides information about its application process and certification fees, as outlined in its fee schedule. If the operation decides to proceed with that certifier, it completes an application, which includes the Organic System Plan (OSP).

Organic System Plan

The Organic System (or Farm) Plan (OSP) is the producer’s opportunity to describe the farm and farming operation to a person who has never seen it. Understanding what is needed and why it is needed makes the process easier. Section 2.5, Organic System Plan, provides more detail about how to develop the OSP.

Farm Map

An accurate map of all farm acreage and production units is typically required as part of the OSP. Important map features include the following:

Field Histories for New Fields and New Farms

Field histories are required for fields if they have no history organic production. To obtain organic certification for a field, a grower must be able to document all materials applied to that field for 36 months prior to the harvest of a first organic crop. The certifying agent then reviews the field history to determine if a field is eligible for certification.

Operator Agreement or Affirmation

The person who signs the operator agreement agrees to adhere to the regulations and affirms that the information supplied to the certifier is correct. This agreement must be signed by the person who has responsibility for making decisions about the operation—typically the farm owner.

Report of Organic Yields and Sales

New applicants will be asked to estimate their projected organic sales. Upon renewal of certification, farmers are required to report the yield and sales of organic products. Ordinarily, the sales are reported in the calendar year during which the money is collected.

Certifier Agent Reviews the Application

The certifier reviews the OSP submitted by the grower and any other documentation required for certification. The certifier must clearly communicate to the applicant in a timely fashion whether the application appears complete and whether the OSP appears to comply with the regulations. If the application is complete and the operation is in compliance with NOP regulations an inspector will be assigned to the operation and will schedule an on-site inspection.

On-site Inspection

Once the certifier’s initial review determines that the operation may be able to comply with the regulations, the certifying agent assigns an organic inspector who calls the applicant to set up an appointment. The inspection must be scheduled within a reasonable time, although it may be delayed for up to six months so that the inspector can observe the relevant land, facility, or activities. For example, if the certifier receives a crop production application during the winter, the inspection may be delayed until the spring or summer when the production season is underway. The purpose of the on-site inspection is to:

The Role of the Organic Inspector

The organic inspector should conduct an opening meeting to discuss the inspection plan. This meeting defines the role of the inspector, communicates the confidentiality of all information, and outlines the planned inspection activities. This is the inspector’s opportunity to set expectations and answer the applicant’s questions. The NOP considers opening meetings to be a best practice for all inspections. Organic inspectors are trained to look critically at all aspects of an organic operation and to maintain strict confidentiality.

Exit Interviews

At the conclusion of the inspection, there will be an exit interview to confirm the accuracy and completeness of the observations and information gathered, addresses the need for additional information, and discusses issues of concern. If significant information is missing, the inspector should note this in the inspection report and discuss this as a concern during the exit interview. The inspector does not make the certification decision, but identifies noncompliance issues with regard to organic standards.

Certifier Reviews the Inspection Report

After the on-site inspection is completed the inspector submits their inspection report to the certifier who then reviews the report and application in order to determine whether or not the operation is in compliance with the regulation. A certification committee, staff member, or review committee reviews the OSP, the inspection report, and all associated documentation. The reviewer will pay particular attention to any issues mentioned in the exit interview and will decide the seriousness of those issues.

Certification Decision

The final decision-maker determines which action is appropriate to the operation. The review of the inspection report may lead to different paths, each of which may require additional evaluations or decisions. After assessing whether the operation appears to comply with the organic regulations, the certifier make one of four certification decisions below and communicates this decision in writing to the operation.

Renewing Certification – Annual Update

The annual update adds new information to the existing OSP. A certified operation must submit an updated OSP and fees to its certifier at least once per year to continue its organic certification. If the operation fails to submit its annual update and/or fees, the certifier issues a Notice of Noncompliance. The annual update must include a summary statement outlining any changes to the OSP that were made during the last year, as well as any changes planned for the coming year. If the certifier requires supporting documentation to verify these changes, then the operation will provide it.

Click on the following topics for more information on organic crop certification.