St. Paul, Minnesota
March 7, 2003

Who needs to be certified?
Producers and handlers who gross over $5,000 in sales of organic agricultural products annually. Like many aspects of the Organic Food Production Act (OFPA) law and NOP regulations, the answer is not as clear-cut as it appears. The exact verbiage exempting smaller operations reads "A production or handling operation that sells agricultural products as 'organic' but whose gross agricultural income from organic sales totals $5,000 or less annually is exempt ... " A custom processor who has income of lower amount, for example $1251 for processing an organic product worth 4 times that amount, would be required to be certified. Operations that handle product valued over $5,000 are required to be certified.

What is Certification about?
It is a process whereby a handler or producers is "certified" by an independent third party as utilizing an organic system as described by OFPA and the NOP. They must be in compliance with the Act and regulations; make, use, and update annually an organic plan; permit inspections; maintain records for 5 years; pay certifiers fees; immediately notify their certifier of application of a prohibited substance and any change in operation that could affect compliance.

When does it need to be done?
The NOP rule became law on October 21, 2002 and applies to all organic product sold in the U.S., whether produced here or not.

Where can certifiers be found?
Any certifier used must be on the NOP accredited list which can be found at www.ams.usda.gov/nop/. All certifiers accredited by the USDA are required to certify all customers using the same standards and procedures. Some organic certifiers, such as the Association of Official Seed Certifying Agencies (AOSCA) groups, have extensive seed and grain expertise. Others have greater expertise in livestock and poultry production and processing.

Timeliness of service varies tremendously between different certifiers. Some are able to complete the certification in about a month. Others are backlogged such that scheduling the inspection process itself requires a couple of months.

Costs also vary by certifier. Generally, non-profit certifiers are less expensive and fairly comparable in price versus for-profit groups. The USDA provides some cost estimates for various size farms (available on their website). A small farm (annual organic sales of $30,000) generally costs less than $1,000 in first year certification fees and less in subsequent years. A farm with annual organic sales of $200,000 requires about $2,000 in first year.

What is the process to receive certification?
An organic production and/or processing plan is developed, the application form is completed and submitted to the chosen certifier. The plan must include descriptions of practices and procedures to be performed and maintained; a list of each
substance to be used; a description of monitoring practices and procedures; a description of record keeping system implemented to comply with requirements; a description of management practices and physical barriers to prevent commingling and contact with prohibited substances; and additional information deemed necessary by the certifying agent. Some of the requirements under the NOP include:

1. The use of organically grown seeds, unless the variety is not commercially available. The same criteria holds true for annual seedlings. Non-organic perennial plants (planting stock) must be managed organically for at least one year prior to harvest of crop or sale of the plant as certified organic planting stock. Organic seedlings and planting stock must be used if commercially available.
    
2. Active management to build soil fertility, manage plant nutrients, protect natural resources, and prevent soil erosion.
    
3. The NOP Rule requires a crop rotation plan that maximizes soil organic matter content, prevents weed, pest, and disease problems, and manages deficient or excess plant nutrients.
    
4. NOP rule requires that organic production areas have distinct boundaries and buffer zones to prevent the unintended application of a prohibited substance or contact with a prohibited substance that is applied to adjoining land not under organic management. To prevent contamination by non-organic products, organic standards have additional rules for farmers who are farming conventionally as well as
   organically.

A minimum of one on-site inspection annually is required. Inspection must verify ability to comply with the Act & regulations; that the information provided is accurate; and prohibited substances have not been and are not being applied. If the operation is found to be in compliance, or have only minor non-compliance issues, the certifier will grant certification. Major non-compliance issues will delay certification or may prevent it entirely.

An operation which has passed certification may then use the word "organic," and if it meets the requirements, utilize the USDA Organic logo on their product.

Why should anyone do this?
It's the law.

The Minnesota Crop Improvement Association hopes this overview has helped to provide a brief summary of a fairly complex topic. It is interesting to note that increases in organic sales have averaged over 20% per year for over a decade and represents the fastest growing segment of agriculture in the US.