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Continuous Improvement and Accountability in Organic Standards

Organic is a voluntary regulatory program for farmers and businesses who choose to meet a strict federal standard and market their products under the USDA organic seal. In fact, the very purpose of the Organic Foods Production Act is to “establish national standards” and “assure consumers that organically produced products meet a consistent standard,” overseen by the USDA National Organic Program. However, the federal regulatory apparatus has stifled innovation and continuous improvement within the industry. In the past 10 years, industry has advanced 20 consensus recommendations for improvements to the organic standards, yet USDA has not completed rulemaking on a single one of them. Learn more about each recommendation below.

We believe that Congress should work with industry to repair the public-private partnership and advance organic standards.

CONGRESSIONAL ASKS FOR CONTINUOUS IMPROVEMENT


BACKGROUND

Industry, environmental, scientific and public stakeholders collaborate and reach consensus on developments to organic standards through deliberation at the National Organic Standards Board (NOSB). The NOSB is a federal advisory committee that meets twice a year and provides USDA with recommendations to advance the standards. 

LEARN MORE ABOUT NOSB


JOIN OUR MEMBER TASK FORCE

The Organic Trade Association task force for Continuous Improvement and Accountability in Organic Standards' mandate is to facilitate a conversation from Organic Trade Association members on repairing the public-private partnership between USDA and the organic industry and generate strategic thinking for how organic will evolve within this partnership over the next decade and beyond.

JOIN US

NOSB Recommendations that have not advanced
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STRENGTHEN ANIMAL WELFARE standards for organic livestock and poultry

NOSB recommends to further clarify and refine the requirements for mammalian and poultry living conditions, stocking rates, heath care, transportation, and slaughter. Several recommendations together support a comprehensive animal welfare program for organic livestock. These recommendations are reflected in the Organic Livestock and Poultry Practices Final Rule which has been withdrawn by USDA. The Organic Trade Association is in active litigation against USDA for failure to implement this regulation.

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CLARIFY the ORIGIN of ORGANIC DAIRY LIVESTOCK

NOSB recommends clarifying and narrowing the requirements for the transition of dairy animals (cows, goats, sheep) into organic milk production as a one-time event. Once a distinct herd has been converted to organic production through one year of organic management, all dairy animals must be under organic management from the last third of gestation. The practice of continuously transitioning and/or cycling dairy animals in and out of organic production would be explicitly prohibited. NOP published a proposed rule that would implement this policy in 2015, re-opened the comment period 2019, but has still has not implemented a final rule.

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PROHIBIT HYDROPONIC and AEROPONIC PRODUCTION

NOSB recommends to prohibit hydroponic production of organic crops, with an exception for mushrooms, sprouts, and micro-greens. NOSB also recommends to prohibit production systems where terrestrial plants are suspended in the air and misted with nutrient rich water.

  • NOSB Recommendation Fall 2010: Production Standards for Terrestrial Plants in Containers and Enclosures
    Prohibit hydroponic production of organic crops, with an exception for mushrooms, sprouts, and micro-greens, and allows container production of organic crops under specific provisions that support natural and diverse soil ecology within the container.
     
  • NOSB Recommendation Fall 2017: Aeroponics
    Prohibits aeroponics systems where terrestrial plants are suspended in the air and misted with nutrient rich water.
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CREATE new standards for GREENHOUSE and CONTAINER PRODUCTION

NOSB recommends to allow container and greenhouse production of organic crops under specific provisions that support natural and diverse soil ecology within the container, while prohibiting hydroponic production. This recommendation would minimize the wide variation currently used by applying the current crop production standards to these production systems. 

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REQUIRE increased used of ORGANIC SEEDS

NOSB recommends to require certified crop producers to demonstrate improvement in sourcing and use of organic seed/planting stock every year. NOSB also recommends a series of improvements to the existing NOP Guidance 5029 Seeds, Annual Seedlings, and Planting Stock in Organic Crop Production that includes both incentives and practical language to aid producers and certifiers in overseeing and encouraging the use of organic seed.

  • NOSB Recommendation Fall 2018: Strengthening Organic Seed Usage
    Requires demonstrated improvement in sourcing and use of organic seed/planting stock every year.
     
  • NOSB Recommendation Spring 2019: Strengthening Organic Seed Guidance
    Clarifies the requirements of the regulatory provision for using organically grown seeds, seedlings and planting stock. The recommendation includes both incentives and practical language to aid producers and certifiers in overseeing and encouraging the use of organic seed.
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CREATE new standards for organic AQUACULTURE PRODUCTION

NOSB recommends to authorize organic certification of aquatic animals including finfish and molluscan shellfish, and establish specific standards for feed, health care, facilities, and living conditions for this unique type of livestock. Aquatic animals are currently excluded from the organic regulations, therefore this series of recommendations would create a new certification scope and market for organic aquaculture products.

  • NOSB Recommendation Fall 2009: Aquaculture: Molluscan Shellfish (Bivalves)
    Establishes specific production standards for organic molluscan shellfish.
     
  • NOSB Recommendation Fall 2008: Aquaculture: Fish Feed, Fish Oil and Fish Meal & Related Issues
    Establishes specific standards for the feeding of fish meal and fish oil to organic aquatic animals under certain circumstances.
     
  • NOSB Recommendation Fall 2008: Aquaculture: Net Pens and related issues
    Authorizes organic certification of aquatic animals and establish specific standards for health, facilities, and living conditions of organic aquatic animals.
     
  • NOSB Recommendation Spring 2008: Farmed Aquatic Plants
    Establishes specific production standards for organic aquatic plants in aquaculture systems. The recommended standards maintain organic principles in the farming of aquatic plants.
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CREATE new standards for organic APICULTURE PRODUCTION

NOSB recommends to establish specific production standards for organic apiculture (honeybee) production. This recommendation would minimize the wide variation currently used by applying the current crop production standards to these production systems.

  • NOSB Recommendation Fall 2010: Apiculture
    Establishes specific production standards for organic apiculture (honeybee) production.
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CREATE new standards for organic PET FOOD products

NOSB recommends to recognize pet food under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on pet food and require compliance with organic standards specific to organic pet food composition, handlings, and labeling.

  • NOSB Recommendation Fall 2008: Pet Food
    Recognizes pet food under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on pet food and require compliance with organic standards specific to organic pet food composition, handlings, and labeling.
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CREATE new standards for organic PERSONAL CARE products

NOSB recommends to recognize personal care products (cosmetics, body care) under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on personal care products and require compliance with organic standards.

  • NOSB Recommendation Fall 2009: Personal Care
    Recognizes personal care products (cosmetics, body care) under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on personal care products and require compliance with organic standards.
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DEVELOP guidance for determining which new technologies are considered EXCLUDED METHODS

NOSB recommends to establish guidance for interpreting the excluded methods provision of the organic regulations. The recommendation includes definitions, principles, criteria that help address the increased diversity in types of genetic manipulations performed on seed, livestock and other inputs used in agriculture. Several recommendations together lists specific technologies and whether they are prohibited under the existing regulatory definition of excluded methods.

  • NOSB Recommendation Fall 2016: Excluded Methods Terminology
    Establishes guidance for interpreting the excluded methods provision of the organic regulations. The recommendation includes definitions, principles, criteria that help address the increased diversity in types of genetic manipulations performed on seed, livestock and other inputs used in agriculture. The recommendation lists specific technologies and whether they are prohibited under the existing regulatory definition of excluded methods. Prohibited methods include: Targeted genetic modification including CRISPR; Gene silencing; Accelerated plant breeding techniques; Synthetic biology; Cloned animals and offspring; Plastid Formation. Allowed methods include: Marker assisted selection; Transduction.
     
  • NOSB Recommendation Fall 2017: Excluded Methods Determinations
    Prohibits cisgenesis, intragenesis, and agro-infiltration under the regulatory definition of excluded methods.
     
  • NOSB Recommendation Fall 2018: Excluded Methods Determinations
    Allows embryo rescue in plants (not prohibited under the regulatory definition of excluded methods).
     
  • NOSB Recommendation Spring 2019: Excluded Methods Determinations
    Prohibit transposons developed via use of in-vitro nucleic acid techniques under the regulatory definition of excluded methods. Clarifies definitions of cisgenesis and intragenesis.
     
  • NOSB Recommendation Fall 2019: Excluded Methods Determinations
    Prohibits induced mutagenesis under the regulatory definition of excluded methods. Allows embryo transfer in livestock (not prohibited under the regulatory definition of excluded methods.
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DEVELOP guidance for RETAILERS about organic compliance

NOSB recommends to provide education and guidance on organic compliance to the retail sector, and clarify several specific sections of the regulations as it applies to retail. These recommendations will also improve consistency and integrity in merchandising, handling and marketing of organic products in retail establishments, and improve consumer understanding of the distinction between “organic” and “certified organic” retailers.

  • NOSB Recommendation Spring 2014: Retail Compliance and Certification
    Provides education and guidance on organic compliance to the retail sector, and clarify several specific sections of the Rule as it applies to retail. Will improve organic integrity in merchandising, handling and marketing in retail establishments.
     
  • NOSB Recommendation Fall 2009: Clarification of Voluntary Retail Certification
    Identifies key areas that need clarification, as well as define the role of NOP, ACAs and retailers in improving the marketing and implementation of USDA organic retailer certification. This recommendation strives to improve consumer understanding of the distinction between “organic” and “certified organic” retailers.
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RESTRICT the use of livestock VACCINES made from excluded methods

NOSB recommends to limit the use of livestock vaccines made from excluded methods only when an equivalent alternative not made from excluded methods is not commercially available to prevent a specific disease.

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RESTRICT conversion of NATIVE ECOSYSTEMS to organic production

NOSB recommends to require a ten-year waiting period between conversion of land supporting native ecosystems and subsequent organic certification.

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DEVELOP guidance on GMO CONTAMINATION PREVENTION strategies

NOSB recommends to identify best management practices for organic operations to prevent of unintended GMO presence in seed and crop production, livestock production, and handling. NOSB also recommends to instruct certifiers to inform certified producers that information on possible genetic contamination of seeds with GMO equivalents could be obtained from their seed suppliers to improve transparency of genetic integrity of seed grown on organic land.

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CLARIFY procedure for calculating ORGANIC INGREDIENT COMPOSITION

NOSB recommends to clarify the requirements for determining the percentage of organic ingredients in multi-ingredient products. The recommendation would make calculations based on "all ingredients", not "finished product", which is consistent with OFPA and NOP. The recommendation would standardize practices for developing self-calculating forms, excluding salt, excluding water, processed-single ingredient calculations, multi-ingredient product calculations, and organic labeling versus organic content.

  • NOSB Recommendation Spring 2013: Calculating Percentage Organic in Multi-Ingredient Products
    Clarifies the requirements for determining the percentage of organic ingredients in multi-ingredient products. The recommendation would make calculations based on "all ingredients", not "finished product", which is consistent with OFPA and NOP. The recommendation would standardize practices for developing self-calculating forms, excluding salt, excluding water, processed-single ingredient calculations, multi-ingredient product calculations, and organic labeling versus organic content. The recommendation also would ensure that the organic community with easily accessible, web based, detailed Guidance on these topics.
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Contact

Megan DeBates
Vice President of Government Affairs
(202) 403-8643