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Material Review Organizations

When an organic operation wants to use an input on their farm or an ingredient in their product, certifying agents must first approve the use of the material by verifying that it complies with the organic regulations.  Certifiers can review specific input ingredient information to determine compliance, or they can rely on the review of inputs conducted by reputable Material Review Organizations (MROs). Organic Material Review Institute (OMRI), Washington State Department of Agriculture (WSDA), and the Environmental Protection Agency (EPA) are examples of MROs widely accepted in the organic industry.  


Organic Material Review Institute (OMRI)               Washington State Department of Agriculture Organic Program               Environmental Protection Agency



OTA strongly advocates for the requirement that MROs become accredited under NOP oversight.
NOP has issued guidance regarding the acceptability of MROs and the products they register; however, USDA does not currently accredit MROs. OTA believes every MRO that takes on the responsibility of material review, allowance, and/or certification must operate under uniform standards and requirements, regardless of whether they are a government entity, certifier, or reputable third party. 
In December 2011, NOSB unanimously passed a recommendation that presented a framework for NOP to actively regulate MROs. The recommendation states, “In order to facilitate adequate oversight and enforcement of the activities of MROs, the National Organic Program should require that MROs become accredited or formally recognized under a newly formed Material Review scope.”
NOP responded to this recommendation indicating their interpretation was that there are legal barriers to creating an accreditation scope for MROs since OFPA stipulates that accreditation is specific to certifying agents.  However, despite these potential legal barriers, OTA continues to advocate for the development of a framework to accredit MROs and bring third party material review under the oversight of NOP.

Scott Rice

Sr. Director, Regulatory Affairs

(202) 695-1268