Transitioning to Organic
Organic certification can provide new opportunities for farmers and their products. However, transitioning from conventional to organic requires both time and a strong business plan. During this transition phase, it is important to understand the various rules and regulations associated with organic certification and how they relate to your operation.
What does it mean to be “certified organic”? I’m interested, but how do I get certified?
Organic certification verifies that your farm or handling facility complies with the U.S. Department of Agriculture (USDA) organic regulations and allows you to sell, label, and represent your products as “organic”. These regulations, administered by the USDA National Organic Program (NOP) describe the specific standards required for you to use the word “organic” or the USDA organic seal.
This webpage provides an overview of the organic certification process and provides additional resources for prospective organic producers and handlers.
What land can be certified as Organic?
To be eligible for organic certification, your land must be free of prohibited substances for 3 consecutive years (see “Guidelines for Organic Crop Certification, USDA NOP”). The USDA organic regulations specify which substances are allowed and prohibited in organic production and handling. While this list is ever-evolving and may change over time, it contains the most updated information of what you can and cannot use on your land in order to comply with organic standards. eOrganic provides a helpful review (see “Can I Use This Input on My Organic Farm”) that walks through the rules and regulations specified in the National List of Allowed and Prohibited Substances.
What if I own a small operation?
If your farm or business receives more than $5,000 in gross annual organic sales, it must be certified (see “Do I Need to Be Certified? USDA”). If your farm or business receives less than $5,000 in gross annual organic sales, it is considered “exempt”. Exempt operations must follow all USDA organic production requirements to sell their products as organic, but they are not required to submit an Organic System Plan (OSP) or pay certification fees. However, exempt farms or businesses may not use the certified USDA organic seal to market their product (see “What farms and businesses are exempt from organic certification?” USDA NOP).
How do I get started?
The first step in transitioning to an organic operation is ending the use of all prohibited substances on the National List of Allowed and Prohibited Substances. During this 36-month transition period, you may not sell, label, or represent the product as organic. It is important to document the last date on which any prohibited substances were applied to the land. It is also important to keep record of land-use practices and all materials applied from the start of your transition process over the three year period. A certified inspector will review these records and information on all material used on the property, including but not limited to: product name, manufacturer name, original or photocopy of label with ingredients (if available), purchase receipts, quantity, and the location of where the material was applied. If you are not the landowner or haven’t owned the land the full three years, you’ll have to provide a signed statement or affidavit that states that no prohibited materials have been used on the property (see “Sample Affidavit of Land Use History” provided by CCOF). Some growers choose to transition their land more gradually, transitioning small parcels of land to organic production over time. Alternatively, growers can look to lease or buy land that has been fallow for at least three years for immediate organic certification.
A good resource to reference throughout the process is the The National Organic Program (NOP) Handbook, which includes detailed information on how to become a certified organic operation.
Who are Organic Certifiers?
After you make the decision to transition to organic production, you should contact an organic certifier. The certifier will provide you with information about the application process and any associated certification fees. The USDA does not certify organic operations directly, but instead, accredits third-party certifying agencies or certifiers to inspect and approve organic producers and handlers. Certifiers verify that farms and processing facilities meet the USDA organic standards. To apply for organic certification, producers and handlers must select a certifying agent. A list of accredited certifying agencies for California can be found here.
Certification costs will vary depending on the certifying agent and size, type, and complexity of your operation. Typically, there is an application fee, annual renewal fee, assessment on annual production or sales, and inspection fees. Certification costs can range from a few hundred to several thousand dollars.
Steps to Certification
Once you have chosen a certifier, the certification process includes the following steps:
- The operation completes an application and develops an Organic System Plan (OSP)
- Each certifier may have slightly different application instructions, but one key document for all applications for organic certification will be the Organic System Plan (OSP). The OSP will describe what your operation produces or processes, what practices you use, and any substances used on the property. You can find an overview of the Organic Systems Plan here and a sample OSP application template here. Additional resources include: Developing an Organic System Plan for Row Crop Production Webinar.
- The operation implements the OSP and the certifier reviews the OSP
- The certifying agent will review your application and verify that your practices comply with USDA organic regulations.
- The certifier’s inspector completes an onsite inspection of the operation to evaluate the implementation of the OSP and the operation’s compliance with the USDA organic regulations
- ATTRA provides a checklists of documentation needed for organic certification which will help organic farmers or handlers be prepared for an organic inspection. Note that inspections are not consulting visits. Inspectors may ask questions, collect and provide information, and explain the regulations or the certifier’s requirements. Inspectors are prohibited, however, from advising the operator on how to overcome barriers to certification.
- The certifier reviews the inspection report
- The final review of the inspection report and certification decision cannot be done by the same person who inspected your operation (see “NOP Separation of Duties in Certification Decisions”).
- The certifier decides whether to grant certification to the operation
To continue certification, you will need to submit an annual update to the OSP and pay certification fees to your certifier. You must notify your certifying agency prior to making any changes to your operation in any way. The annual update only needs to describe changes you have made in your operation and does not need to reiterate information that was previously submitted in the OSP. The certifier will once again review your OSP, complete an inspection, and determine if you are complying with USDA organic regulations.
It is important to keep records for all of your activities and purchases to show compliance with organic standards. There are no requirements about how you record the information, but it must be done in a written format that an organic inspector will be able to understand (see “Recordkeeping Checklist for Organic Growers” provided by CCOF). The USDA provides instructions on recordkeeping requirements and includes examples of types of records that should be maintained in conjunction with a certified operation’s OSP.
The UC Sustainable Agriculture Research and Education Program (SAREP) put together a helpful guide on Organic Compliance that includes an Organic Practice Guide (pg. 3), a summary of the USDA National Organic Program Rule (p. 18), an Organic Systems Plan Overview (p. 34), Materials Used in Organic Farming (p. 37), Organic Seed and Seed Sources (pg. 39), and other useful information regarding organic compliance.
Resources for Specific Certification Categories
The USDA recognizes four categories of organic products:
- Processed products
- Wild crops
The National Organic Program's (NOP) Organic Rule §205.103 states that "a certified operation must maintain records for production, harvesting and handling of organic agricultural products…" The operation’s recordkeeping system must be sufficient to be "readily understood and audited". Below, we outline important recordkeeping practices for each certification category.
Recordkeeping must be sufficient enough to trace each crop from field to harvest, storage and sales, including the application of soil amendments, pest or disease control products, and other inputs. The “ABCs of Organic Certification Webinar” provides a background on the National Organic Program, organic crop requirements, and organic certification. The USDA also has a Guide for Organic Crop Producers that helps guide farmers through the organic certification process for crop production.
Farm records that meet NOP requirements can be grouped into the following categories:
- Farm and field maps
- Field history sheets
- Seed purchase records
- Organic Seed and Planting Stock Regulations and Resources – find an overview of regulations, recordkeeping requirements, and a list of organic planting stock and seed suppliers
- Organic Seed Producers Directory – Organic Seed Alliance
- Sample seed and planting stock record
- Sample Seed Commercial Availability Search Record – use this form if an organic equivalent of the seed and planting stock you are looking for is not available
- Sample Input Record
- Check out The Organic Materials Review Institute (OMRI) to find input products allowed for use in organic production and processing
- If you want to use a material that does not appear on the OMRI or WSDA allowed materials list, you must check with your certifier before using this material. For most, you should fill out a Material Review Requestform
Check out this webinar from CCOF that outlines the Organic Certification process for greenhouses and reviews some basics of organic greenhouse production, such as potting mix selection and pest control.
A great place to start for livestock producers is CCOF’s “An Introduction to Organic Livestock Production”. The USDA’s Guide for Organic Livestock Producers is also a great resource that provides an overview of the process of becoming certified organic for livestock producers.
It is important to seek approval from your certifier before using new health care materials, feed additives, and supplements within your operation. Feed supplements, additives and any land used for grazing must all be certified organic. All updates must be made on your Organic System Plan (OSP) and submitted before inspection. Recordkeeping, including but not limited to feed harvest records, feed purchase records, feeding records, grazing records, health care treatments, and vaccination records are important to document for maintaining organic certification. The Guide to Livestock Producer OSP Forms is helpful to understand what forms you need to apply for and comply with organic certification standards. For CCOF certification, you will need to fill out a New Livestock Application and a Livestock Materials Application (OSP Materials List).
If raising cattle, sheep, goats, or other ruminant livestock, you will also need to fill out a Pasture Management Plan. If you plan to graze animals at other certified operations and/or provide grazing services for animals that you do not own, you must fill out a Custom Grazing and Management Affidavit. A Grower OSP Forms is required for ranchers that provide organic pasture and/or livestock feed. CCOF also has a program for Certified Grass-Fed Organic Livestock. However, if you plan to process products (cook, cure, slaughter, etc.) or perform post-harvest handling at a facility, you will need to fill out applicable Handler OSP Forms.
- Processed Products:
A great place to start for processors is CCOF’s “Demystifying Organic Certification for Processors”. The USDA’s Guide for Organic Processors also provides a comprehensive guide for farmers who want to add value to their organic crops through processing.
The Guide to Handler OSP Forms is helpful for identifying which forms are needed when applying for organic certification for an organic business. There are forms for those who: contract independently certified facilities to produce or label a product; act as a broker, trader, wholesaler, distributor, or importer of organic products; process, handle, or physically label organic products; etc.
If operating out of a home kitchen, this webinar covers the specifics of the cottage food laws in California and Washington states, reviewing cottage food registration, what types of licenses you’ll need, and product labeling requirements. For organic growers who may be considering experimenting with value-added products, the video also discusses organic labeling requirements and how to market value-added products in compliance with organic regulations.
- Wild Crops
Wild crops refer to plants and/or plant material that is gathered or harvested from a location where cultivation or agricultural management is not practiced. For wild crops to be eligible for organic certification, your land must be free of prohibited substances for three consecutive years. CCOF provides a useful Guide to Wild Crops OSP, as well as a parcel application to aid growers in documenting land-use history for verification during the organic certification process.
Is there any support available?
Transitioning to organic production can be a complicated and costly process. As such, there are a number of technical assistance providers that can help you navigate the rules, regulations, and processes associated with applying for and maintaining organic certification. Financial resources are also available for growers to help offset the initial costs of transitioning to organic production.
- Your local UC Cooperative Extension Farm Advisor can provide support and information on best management practices.
- California Resource Conservation Districts (RCDs) provide resources for natural resource conservation and agriculture on public and private lands at local, regional, state, tribal, and federal levels.
- ATTRA has a lot of resources about Organic Farming as well as Sustainable Agriculture Specialists that can provide technical assistance
- CCOF Chapters - (for CCOF members only) Chapters help CCOF members maintain successful organic businesses by providing speakers at chapter meetings, networking opportunities with potential buyers, and connections to farming organizations and resources. Most chapters meet a few times per year and engage in topics important to their region/sector. If you would like to get involved in your CCOF chapter, find your local chapters here and contact your chapter leader to find out about chapter meetings and activities.
- The Natural Resource Conservation Service (NRCS) offers financial and technical assistance to farmers choosing to implement a new organic management standard. Find your local NRCS office here
- The USDA is rolling out a Transition to Organic Partnership Program (TOPP) to connect transitioning farmers with mentors and technical assistance. CCOF is taking the lead on building out a mentorship program for California, which will include support from the UC OAI. Recruitment is set to begin by July 2023 and participants will be matched with mentors by Fall 2023. If you are interested in participating as a mentor or a mentee, fill out this interest form.
- Rodale Institute Organic Consulting – free consulting services for farmers, which includes a site visit and 10 hours of time. This can include agronomic advising, help with crop planning, budgeting or filling out certification applications.
- Organic Certification Cost Share Program- provides cost share assistance to producers and handlers who are obtaining or renewing certification under the NOP. Certified operations may receive up to 75% of their certification costs paid during the program year
- This fact sheet from USDA provides an overview of the program. You are eligible to apply for reimbursement of costs you incurred in paying for certification fees - these costs can include inspection costs, travel/per diem for inspectors, user fees, sales assessments, and postage
- The maximum reimbursement amount is $750
- You can apply directly in your local FSA office
- The Natural Resource Conservation Service (NRCS) has an Environmental Quality Incentive Program (EQIP) Organic Initiative to provide technical and financial assistance for those interested in transitioning to organic. If you are interested in applying for EQIP funding, reach out to your local NRCS office to learn more. Click this link to find your local NRCS office.
- CCOF has an Organic Transition program where they offer $10,000 per year for 3 years to off-set the cost of transitioning.
- The USDA has the Transitional and Organic Grower Assistance Program to provide financial support for farmers transitioning to organic. Note that this program is offered through USDA’s Risk Management Agency (RMA) and connected to crop insurance – therefore, a farmer must have an insurance policy to be eligible for this program. The USDA RMA is offering a premium subsidy for all Whole Farm Revenue Protection (WFRP) policies, which is an insurance option for diversified producers and those growing specialty crops not covered by commodity crop insurance. Through WRFP, there is also the new Micro Farm program for farmers making less than $350,000 per year. You can reach out to a local crop insurance agent to see what options are available.
- Organic Market Development Program Grant (OMDG)- will help improve key organic markets where the need for domestic supply is high or where additional processing and distribution capacity is needed for more robust organic supply chains. OMDG offers three project types, 24-month Simplified Equipment-Only with funding between $10,000 and $100,000. 3-year Market Development and Processing Capacity Expansion with funding ranging between $100,000 and $3,000,000. There is approximately $75 million available to fund OMDG projects in 2023.
Learn more about the USDA’s efforts to support organic agriculture through The USDA Organic Transition Initiative, which will provide mentorship, direct farmer assistance, and development of organic markets.