Maintaining Your Organic Certification

Annual recertification exists to ensure that organic operations continuously meet NOP standards — not just at the moment of initial certification. It is the mechanism that gives the USDA Organic seal its enduring credibility and market value.

Farming is dynamic. Fields are added or removed, new inputs are considered, practices evolve, and risks change year to year. Annual renewal ensures that:

• Your Organic System Plan reflects your current practices

• Any changes to your operation have been reviewed and approved

• Your certifier can verify ongoing compliance through annual inspection

• Records are maintained and current

Annual renewal also protects consumers and the organic marketplace. According to the Accredited Certifiers Association (ACA), the annual inspection cycle is one of the key safeguards that distinguishes certified organic from unverified organic claims — and it is one of the features that the SOE rule was designed to further strengthen throughout the supply chain.

Annual organic recertification follows a consistent process that, once you are familiar with it, becomes a routine part of farm operations:

1. OSP Update: Review and update your Organic System Plan to reflect any changes to your operation from the prior year — new fields, new inputs, new crops or livestock, changed practices.

2. Records Compilation: Gather your year's records — input receipts, field logs, harvest records, sales records, and equipment cleaning logs — to have available for your certifier's review and for the inspection.

3. Annual Fee Payment: Pay your certifier's annual certification and inspection fees. Save receipts — these are your OCCSP reimbursement documentation.

4. Application Submission: Submit your updated OSP and any required renewal documentation to your certifier by their deadline.

5. On-site Inspection: Host your annual inspection, ensuring your records are organized and your operation is audit-ready.

6. Certificate Renewal: After a successful review and inspection, your certifier issues a renewed Certificate of Organic Operation.

7. OCCSP Application: Submit your annual OCCSP cost-share application to your USDA FSA Service Center for reimbursement of certification costs.

Preparation is the key to a smooth annual inspection. Producers who maintain good records year-round report that inspections are straightforward and low-stress. Here's how to prepare:

Before the inspection:

• Organize all records for the year — inputs, field logs, harvest records, and sales — in a format that matches your OSP

• Review your current OSP and confirm it accurately reflects your operation

• Verify that all inputs currently on hand are on your approved input list

• Check that equipment cleaning/sanitation logs are complete (especially critical for split operations)

• Do a self-audit of your fields and facilities using your OSP as a checklist

During the inspection:

• Be present and available to answer questions

• Make records easily accessible — either in hard copy binders or digital access

• Be straightforward about any challenges or changes that occurred during the year

• Ask your inspector to clarify any questions you have about compliance

The ACA's ACAdemy training program offers inspection preparation resources that can help producers understand what inspectors look for.

NOP regulations (7 CFR § 205.103) require certified operations to maintain records that:

• Disclose all activities and transactions of the certified operation in sufficient detail to be readily understood and audited

• Cover the entire period covered by your certification

• Are maintained for a minimum of 5 years

Specifically, you must maintain records for:

Crop Production:

• Field history and soil amendment records

• Seed and planting material sources and search documentation

• All inputs applied (what, when, where, rate, and documentation of allowed status)

• Pest, weed, and disease management activities

• Harvest records with lot or batch numbers

Sales & Marketing:

• Organic sales invoices linking specific harvests to buyers

• Transaction certificates and organic certificates of products purchased

For Livestock:

• Feed source, composition, and purchase records

• Health records and documentation of any veterinary treatments

• Livestock origin documentation

Quick Organics' Digital Filing Cabinet stores all of these record categories in one place, with access from any device.

Under 7 CFR § 205.103, certified organic producers must maintain all records for a minimum of 5 years beyond their creation.

This 5-year retention requirement applies to:

• All field activity logs and input application records

• Input purchase receipts and invoices

• Harvest records and lot tracking documents

• Sales records and transaction certificates

• Equipment cleaning and sanitation logs

• Any correspondence with your certifier regarding input approvals or compliance

Best practice — and the approach recommended by the ACA — is to maintain records indefinitely in digital form, since storage costs for digital records are minimal and longer retention reduces risk in the event of a compliance dispute or investigation.

Quick Organics' Digital Filing Cabinet retains all records securely and indefinitely, ensuring you never need to worry about missing records at inspection time.

After years of working with certified producers and certifiers, the ACA has identified record-keeping habits that distinguish producers with smooth annual inspections from those who struggle:

1. Record inputs at the time of use, not retroactively: A receipt is not a field activity record. Note what was applied, to which field, at what rate, and on what date — as it happens.

2. Keep input labels on file: Every material used must have its label retained, not just the receipt. Input labels are required during inspection.

3. Document every change immediately: If you add a new field, switch to a new input, or change a practice, notify your certifier and update your OSP promptly — not at renewal time.

4. Maintain lot traceability: Every harvest should have a lot number that can be traced from field to buyer. This is increasingly required by buyers and is essential for SOE compliance in the supply chain.

5. Keep your OSP current: An OSP that doesn't match what you're actually doing is a compliance risk. Review it at least twice a year.

6. Store records in one place: Scattered records are the most common source of inspection stress. Quick Organics' Digital Filing Cabinet centralizes everything.

Determining whether a specific input material is allowed in certified organic production is a two-step process:

Step 1 — Check the National List:

The USDA's National List of Allowed and Prohibited Substances (7 CFR §§ 205.600–205.606) is the definitive legal authority on what is and isn't allowed in organic production. It lists synthetic substances that are allowed and natural substances that are prohibited. The National List is publicly available through USDA AMS.

Step 2 — Check OMRI and other approved product lists:

The Organic Materials Review Institute (OMRI) maintains a list of products that have been reviewed for compliance with organic standards. OMRI listing does not replace your certifier's approval, but it is a strong indicator of likely compliance.

Step 3 — Confirm with your certifier before use:

For any material where you are unsure, always confirm with your certifier before applying it. This is especially important for materials that are allowed only under specific conditions — such as when a natural alternative is commercially unavailable. Using an unapproved material — even inadvertently — can result in a non-compliance notice.

Accidental use of a prohibited substance is one of the most stressful situations a certified producer can face — but how you handle it matters enormously.

What to do immediately:

1. Stop use immediately upon discovery

2. Document what happened: what was used, on which field(s), at what rate, and on what date

3. Contact your certifier promptly — do not wait until annual renewal. Voluntary, timely disclosure is treated far more favorably than discovered non-compliance.

What your certifier will do:

• Investigate whether the application affected the organic status of the land or product

• Issue a Notice of Noncompliance describing the issue and required corrective actions

• Determine whether the affected products can still be sold as organic, must be withheld pending investigation, or must be sold as conventional

Consequences can range from a corrective action plan with no loss of certification (for minor inadvertent incidents with prompt disclosure) to a more serious outcome if the incident was significant, undisclosed, or repeated.

The key lesson: maintain systems that prevent accidental use, such as clearly labeling storage areas and maintaining approved input lists at the point of use.

Yes — OMRI listing is not a requirement for a product to be used in certified organic production. OMRI listing is a third-party review process that indicates a product has been evaluated for compliance with organic standards, but it is not the legal standard itself.

What matters legally is whether the product complies with:

• The National List of Allowed and Prohibited Substances (7 CFR §§ 205.600–606)

• Any restrictions on use documented in the National List

• Your certifier's review and approval

Other approved product review programs also exist, including:

• WSDA (Washington State Department of Agriculture) organic input review

• Organic Materials Review Institute Canada (OMRI Canada)

• Some certifiers maintain their own approved input lists

Always confirm with your certifier before using any non-OMRI-listed product. Providing your certifier with the product's ingredient list and Safety Data Sheet will help them make a determination.

A split operation — one that produces or handles both organic and non-organic products — is entirely permissible under NOP regulations, but requires a rigorous system to prevent two specific risks: contamination (contact between prohibited substances and organic products) and commingling (mixing of organic and non-organic products).

Required practices for split operations:

Physical Separation:

• Store organic and non-organic inputs in clearly labeled, physically separate areas

• Use separate, dedicated equipment for organic operations where possible

• Where equipment is shared, maintain a documented cleaning and sanitation protocol that is completed and logged before organic use

Record-Keeping:

• Maintain separate field maps clearly identifying organic and transitional fields

• Keep separate harvest, storage, and sales records for organic vs. conventional products

• Document every equipment cleaning event

Labeling & Identification:

• Use clear, durable signage on bins, storage areas, and containers

• Apply lot numbers that allow complete traceability from organic field to organic buyer

Your OSP must describe your split operation management system in detail. Inspectors pay particular attention to split operation controls during annual inspections.

A Notice of Noncompliance is a formal written notification from your certifying agent that your operation has been found to be in violation of one or more NOP requirements. Receiving a Notice of Noncompliance does not automatically mean your certification will be suspended or revoked.

Common reasons for a Notice of Noncompliance:

• Incomplete or inaccurate records

• Use of a non-approved input

• Failure to update your OSP to reflect operational changes

• Commingling or contamination of organic products

• Missing or incorrect product labeling

How to respond:

1. Read carefully: Understand exactly what the certifier identified as non-compliant

2. Respond within the stated deadline: Certifiers issue a specific timeframe — typically 10–30 days — for a response and corrective action plan

3. Provide a corrective action plan: Explain what caused the noncompliance and what specific steps you will take to correct it and prevent recurrence

4. Provide supporting documentation: Back up your response with relevant records

If you disagree with the certifier's determination, you have the right to request a mediation process or file an appeal with USDA AMS.

Building connections with other certified organic producers is one of the most valuable investments you can make in your organic operation. Here are the best ways to connect:

Events & Conferences:

• NOSB Public Meetings (held twice annually): Open to all stakeholders — producers, certifiers, and consumers. A valuable opportunity to engage directly with organic standards development (ams.usda.gov/NOP)

• Organic Produce Summit (OPS): Annual conference connecting organic producers, buyers, and certifiers (organicproducesummit.com)

• Rodale Institute's Annual Organic Field Day: Hands-on regenerative organic research and education (rodaleinstitute.org)

• Pennsylvania Certified Organic's Growing Together Conference: Regional event focused on organic transition and certification (paorganic.org)

Organizations:

• Accredited Certifiers Association (ACA): Connects certifiers and producers, with educational resources through ACAdemy (acaorganic.org)

• Organic Trade Association (OTA): Industry organization representing organic producers, processors, and retailers (ota.com)

The Accredited Certifiers Association (ACA) is the professional organization for USDA-accredited certifying agents, and it also offers resources that directly benefit producers navigating the certification process.

ACA's ACAdemy is the association's training and education platform, which offers:

• Online courses covering organic certification fundamentals, record-keeping, and compliance

• Training modules designed for both certifier staff and organic producers

• Resources on the SOE rule and its implications for certified operations

• Guidance on Organic System Plan development and inspection preparation

ACA also provides:

• A searchable directory of member certifying agents

• Policy updates and regulatory guidance for organic stakeholders

• Webinars and educational events throughout the year

For producers, ACAdemy is particularly useful for understanding what certifiers look for during inspections and how to build records that are audit-ready. Quick Organics recommends ACAdemy as a complementary educational resource.