Prior to becoming an organic crop consultant at Rodale Institute, I spent four years reviewing organic system plans, conducting inspections, and reviewing fertilizers, pesticides and other crop inputs used by organic farmers.
When I left the regulatory world, I was surprised to find out that there was a lingering sense of distrust among farmers on whether organic products being imported are being held to the same high standards that domestic certified organic farmers are held to.
As a longtime defender of the organic standards, I would like to share my insight on compliance and enforcement, and what that truly means in practice. I was at the front line of organic integrity. It was up to me and an army of compliance specialists all over the world to verify that every certified organic producer was following the rules and not cheating the system.
Organic compliance specialists and auditors are held to strict standards of confidentiality. I cannot divulge any information about a client’s acreage, methods for growing or materials used, and I surely cannot tell you all about any past transgressions of local producers. What I can say, though, is that fraud happens but the offenders are almost always caught.
There are a few examples of organic fraud making its way into the mainstream: the 2016 Saul Farms alfalfa seed fraud, the 2017 Eastern European import frauds, and the 2018 Field of Schemes activities in Nebraska. In each of these scenarios, the swindlers were charged and action was taken by the National Organic Program to prevent this activity from occurring in the future.
In August of 2017, the USDA NOP released a memo that implemented additional control measures for accredited certifying agents of organic products in Eastern Europe and Turkey to increase oversight of organic grain production and sale. This included unannounced inspection and residue testing to occur at any operation certified in the region, as well as sampling and analyzing for the presence of pesticide residue and genetically modified organisms.
These test results, copies of noncompliances and responses to the noncompliances were required to be sent from the accredited certifying agencies to the NOP.
The result of this Organic Grain Directive was that 180 operations in the Black Sea region lost their USDA organic certifications after they failed unannounced inspections and residue testing. Trade data showed imports from this region declining from 49% to 21% between 2016 and 2018. Certifiers continue to work in this region to ensure organic integrity of all imports under strict scrutiny. Many certifiers now require yield-per-acre calculations and additional unannounced inspections.
Even after the success of the Organic Grain Directive, the National Organic Program and local certifying agencies continue to work hard to protect the organic integrity abroad and domestically. The NOP has since written and proposed a new rule called Strengthening Organic Enforcement (SOE).
This rule includes fewer exemptions of certification, increases requirements for handler certifications, requires electronic import certificates for shipments of organic products, develops a more robust organic reviewer and inspector training protocol, and increases oversight of accredited organic certifiers. The NOP published this proposed rule on Aug. 5, and it stayed open for comments until Oct. 5. During that time, 1,525 comments were received. As the NOP reviews those comments and considers additional edits to the rule, those close to the industry are keeping their ears to the ground in hopes that this proposed rule becomes a final rule and is published soon.
The organic industry will no doubt benefit from increased oversight from this rule. When businesses are given clear and consistent regulations and tools to ensure compliance, this will result in stronger consumer and farmer trust in the USDA label and a level playing field for all certified organic farmers and businesses that are doing their best to protect the organic seal. If you want to learn more about the SOE rule, you can contact your organic certification agency.
All of us, consumers and farmers alike, have a role to play in ensuring integrity of the organic supply chain. If you are purchasing organic grains, know your supplier, the products and associated risk, and fully understand the supply chain. If you are selling organic products, talk to your buyer about how they can or would prioritize your products over imports and support local farmers.
If you are interested in becoming certified organic or learning more, contact the Rodale Institute organic crop consulting team at firstname.lastname@example.org or call 610-683-1416.