Inside Organics Blog

Organic certification needed to reclaim ‘organic’ label

By Harriet Behar, MOSES

Being a certified organic farmer or certified organic operator of any type is an achievement that reflects a producer’s commitment to a healthy planet and is one that deserves its excellent reputation in the marketplace. The strict yet practical standards that are followed, and the exceptional traceability of activities, inputs and ingredients, results in a high quality finished product that is sought after in the marketplace at a premium price. However, while we find farmers and consumers still attracted to organic practices and products, organic certification does not carry the same attraction that it once had. It is time to re-energize the certified organic brand and recognize the superior stewardship and accountability of producers who go through this rigorous process to use the organic label.

For many years the organic community has stated that organic is the gold standard of agricultural production. Our attention to protecting and enhancing the natural resources of the land we steward, coupled with the avoidance of applying toxic materials to our land and the crops we produce is the foundation of what we do as certified organic farmers. As an organic inspector in the 1990s and 2000s, I would visit many types of organic farms in the Upper Midwest and see the organic certificate proudly displayed in a place of honor on the wall with the wedding pictures and other family photos.

However, in the past few years, I have seen less enthusiasm among those who are certified organic, even to the point of some seeing it as a necessary evil whose only value is that it offers access the organic marketplace—some even appear to be ashamed of their participation in the certification system. Many noncertified farmers state that they are “beyond organic” or “better than organic,” confusing consumers and lessening the value of the organic certificate for those who are certified.

Even some longtime advocates and allies of organic agriculture are stating that the organic certificate no longer has the same meaning, due to concerns relating to governmental oversight of the organic standards and the lessening of transparency in decision making. I have at times called for changes to the National Organic Program’s implementation of the Organic Food Production Act and the regulations, but I still have a deep belief that our certification system and the rules under which all organic farmers and handlers must operate in order to carry the organic seal results in products and a verified production system that provides the only sustainable future for agricultural production.

Are the organic regulations perfect with no gray areas or inconsistencies? No, this relatively young regulatory system has had some rough patches in implementation, but we have also continually been improving the standards to close loopholes, and still provide farmers with standards that are practical and achievable. Things could have been much different. The standards could have been very weak, with little to no differentiation between organic and non-organic products, or minimal to no accountability that organic operators were meeting the standards. Or there could have been exceptionally elite or impractical rules that only a very few could accomplish by spending a lot of dollars or by implementing complicated management tools.

Our system of organic certification, with the accompanying organic certification cost share is accessible to any farmer or operator who is willing to follow the foundational principles of organic management, and maintain basic production and sales records to prove their activities. These records also help farmers improve their operations by maintaining historical records they can use when making current and future management decisions. The continual improvement and experimental nature of organic farming encourage organic farmers to be the heart and hands of a system that seeks out solutions that actually improve our ecosystems—from the soil below our feet to the crops, livestock, humans and wildlife that rely on a complex and interrelated use of natural resources for their sustenance. Soil, water, air, plants, wildlife, insects, reptiles, bacteria, etc. are all important to a biodiverse ecosystem. It is the certified organic label and its governmental enforcement capabilities that ensure the promotion of healthy and respectful interactions within an agricultural production system.

Those who “follow organic practices” but choose not to join the community of certified organic operations have many reasons, and feel somewhat cheated they cannot use “organic” to describe their activities and finished products. I have no doubt that many meet the organic regulation in their fields, although perhaps not all of the documentation requirements.

However, it is the traceability and accountability of certified organic production that provides consumers with the confidence they seek when purchasing something with the organic label. Maintaining detailed records helps the farmer develop healthy crop rotations and track production problems, and tweak the farm system over time to deal with these issues. Having more “eyes”—those of the organic inspector and certifying agent—can be useful in finding areas that need improvement and dealing with problems from a systems-based approach, not just substituting an organically approved product in place of a non-organically approved one.

Improving the certification system to lessen the “hassle factor” is a focus of the NOP’s Sound and Sensible initiative; I can say that, as a certified organic producer, I have recently experienced a more producer-friendly inspection and certification renewal.

The relationship between certifier and operator is essential to keeping up with changing organic regulations and clarification of existing ones, from systems to allowed inputs. The verification that branded inputs do not contain nondisclosed problematic and toxic materials can only be done by an organic certification agency or an entity such as OMRI (Organic Materials Review Institute). These government-accredited businesses can enter into confidentiality agreements with manufacturers, so the company releases the full list of ingredients and the certifier can then verify compliance to the organic law. Those who are not certified organic are relying on incomplete information when making input or ingredient choices.

Agricultural inputs do not have the same ingredient label disclosure laws that human food does; it is surprising how many toxic materials can be included, for instance, under the “inert” designation on pesticides. Even human food labeling does not always require listing all items included as sub-ingredients, such as synthetic flowing agents in salt, on the final consumer label. The fact that sewage sludge might have been used to grow the agricultural ingredients in a product is definitely not noted on a food label. The consumer trusts the organic certification process to make sure the rules are consistently implemented across all organic products.

The word organic has a positive association in the marketplace. Many who wish to ride those coattails are doing this with a variety of words such as natural, responsible, or simple. None of these words have either the definition or force of law behind them to verify their actual or assumed claims.

Consumers and farmers can be deceived that a product is comparable to one bearing the organic seal when labeled “natural” or perhaps even “better than organic.” I had one noncertified producer state that since a certain material he does not use is allowed in organic, his product is better than that of certified organic producers. I had to clarify for him that just because a material is allowed,
it does not mean that every organic producer is using it or even mandated to use it, and that since he is not certified, there is no oversight that his claim to not use this material is true.

So many claims in the marketplace have little to no standards, and many do not match consumers’ assumptions. Fresh eggs technically means eggs that have never been cooked. Free-range chickens are not in cages, but they do not have to go outside and no one is actually verifying this claim. “No-spray” on a farmers’ market sign does not mean a farmer was not using synthetically treated seeds, insect dusts or chemical fertilizers. Producers using these claims are nowhere near meeting the USDA definition of organic, but by using the phrase “no-spray” they are playing to the consumer’s desire to purchase something that meets the organic regulations.

Various retailers are putting in place other “scoring” programs, which include fair trade, good employee policies and giving more points to the score when pesticides are used according to EPA guidelines, even if these pesticides are not organically approved. There is an opening for these new private labeling systems because consumers and farmers are not truly understanding the depth and breadth of our organic certification system and the integrity that it represents. Signing a form that you meet the requirements of a labeling program, or having a neighbor who themselves is not deeply versed in the details of the organic regulation verify your compliance, does not provide the same guarantee of integrity and best practices to protect the environment and human health as organic certification provides.

It is time for those who want to use “organic” to overcome their reticence and join with their fellow organic producers and become certified.

It is also time for certified organic producers to educate consumers about the many benefits and guarantees of organic certification. Organic certification is still the “gold standard” that ensures the products being sold have been verified as being grown to nationally approved regulations.

Harriet Behar, MOSES Senior Organic Specialist, answers farmers’ questions about certification and organic practices. Email her at

From the July | August 2015 Issue



July 8, 2015

I have seen soil test of well run organic farms that have phosphorus levels that rival conventional dairy farms – as in off the chart.  The reason being they are using compost and/or composted chicken manure to meet the nitrogen needs while over fertilizing  phosphorus and potassium.  Is there nothing in the organic rules to prevent this?  Why are organic farmers not required to buy their N, P, K, S Mg etc separate and custom blend fertilizer to crop needs based on soil sample results? Why are organic farms required to submit soil sample results if those results are not looked, rather just filed away and the box on the application for soil sample results is checked?  The folks I know who applied for organic certification said the inspector was very interested on the plan to increase deficit nutrients, i.e. what type of fertilizer was going to be used, but made no mention of a plan to lower very high levels of nutrients.  Just wondering.

Alan Baker

Harriet’s response:

I was an organic inspector for 20 years, and when I saw excessive nutrients, especially phosphorus, it was mentioned in my reports.  I know of other inspectors who do this as well.  Protection of our natural resources, including soil and water quality, is part of the organic regulation, as is a soil-building rotation that includes application of plant and animal materials in a way that would not contribute to excessive nutrients running off into surface waters. In addition, excessive phosphorus would also result in a lot of grassy weed pressure, which would make the organic farmer’s weed management more difficult. Solid manure applications have less soluble phosphorus than synthetic phosphorus applications, and tend to be a little less mobile, so the soil test may not be a true picture of the problem, but high levels of phosphorus from any source should be addressed.

There are other sources of N, that would have less P in relationship to the N such as fish powder, kelp, feather meal, or blood meal, but I am not sure if these are as readily available for purchase nor if they come pelletized like poultry manure. Pelletized fertility inputs are easier than powders to apply through standard fertilizer application equipment.

I can’t speak to why the organic certification agencies in your region do not look at and comment on soil imbalances noted in submitted soil tests by their certified organic farmers. The certification agencies active here in the Upper Midwest I know have made comments on the soil test results, and to my knowledge, do request the farmer to address these issues. They cannot mandate custom-blended fertility inputs, but they can mandate remediation of any problems they find.

July 11, 2015

I have a lot of respect for the organic label and certification, and I agree with your sentiment. However we raise animals, and neither our pigs or chickens are vegetarian. Since organic rules require they be fed vegetarian feed, I have shied away from certification. Our pigs get good meat raised on pasture, very close to (if not meeting) organic standards. I don’t have any plans to stop feeding them something they are well known for wanting in their diet.

Shaun Murphy

Harriet’s response:

Thanks for taking the time to comment on my Inside Organics piece about organic certification. I understand your reticence to give vegetarian feed to omnivores. This issue has been discussed at the National Organic Standards Board under the umbrella of promoting animal welfare and respecting the natural behavior of organic livestock. 

Unfortunately, the organic meat industry is not mature enough at this time to provide offal and scraps to the organic livestock and pet food industries.  Once there is sufficient volume of organic meat seconds, close enough to processing facilities producing organic feeds, we might have an option for organic livestock producers who wish to buy organic feeds containing organic meat products.

I think some organic consumers believe vegetarian feeds are in some way superior to non-vegetarian feeds. That is also a challenge to developing the infrastructure and volumes needed to produce non-vegetarian organic livestock feeds, since the total volume of organic livestock feeds produced will be split between non-vegetarian and vegetarian feeds, making it even more difficult to reach the volumes needed for a non-vegetarian option.

Since non-organic livestock feed has antibiotics, hormones, genetically modified ingredients, fungicides, mold inhibitors and more non-organic livestock feed cannot be used for organic livestock. The only possible exception to this is the proposed allowance of feeding non-organic fish to organic fish to then have an organic fish labeled USDA organic. This has not yet been published in the federal register by the National Organic Program, but it was recommended by the National Organic Standards Board this spring. This exception is controversial within the organic community.

August 31, 2015

From Harriet’s Blog: “I have at times called for changes to the National Organic Program’s implementation of the Organic Food Production Act and the regulations, but I still have a deep belief that our certification system and the rules under which all organic farmers and handlers must operate in order to carry the organic seal results in products and a verified production system that provides the only sustainable future for agricultural production.”

I have tremendous respect for the MOSES organization and Harriet Behar for her many years of dedicated service. However, I find the sentiments expressed in this blog to be  counter-productive to building a genuinely sustainable food system.  Having worked in organic certification for over twenty-five years, I have to scratch my head at Harriet’s conclusion that “only” certified organic farms are part of a sustainable future for agricultural production. I can think of many certified organic operations that I don’t see as having a part in a sustainable future, and certainly many, many non-certified farms that most assuredly do. I think it inadvisable to portray organic certification as the be-all-and-end-all of sustainability. Representing it as such results from confusing organic agriculture, which is indeed the only sustainable future our planet has and one we need to embrace rapidly and organic certification, which is a federally-operated process verification program which very loosely models the principles of organic agriculture. It does more harm than good to try to represent organic certification as a proxy for organic agriculture.

There are two aspects of the “gold standard” philosophy (and bear in mind what the US government did to the original gold standard) that are especially troubling to me.  One, it disrespects conventional farmers by telling them – and their customers – that they are not part of a sustainable future. Wonder why some of those non-certified farmers have a chip on their shoulders regarding certification? Secondly, stating that USDA certification is a necessary step for sustainability really dis-empowers people from making an intelligent informed decision on their own. Why is it exactly that people are incapable of figuring out for themselves what a sustainable future looks like and therefore have to have the USDA tell them what it looks like? I don’t want to bring political philosophy into this – the science itself establishes that organic certification has grave limitations – but really, why do you think people are incapable of making intelligent decisions for themselves?

No thanks, but rather than buy fruit shipped 2,500 miles I will continue to buy the awesome apples, peaches and pears from my local farmers who cannot comply with an arbitrary USDA organic standard which precludes growing certified fruit in a four season climate. The only sustainable food future we have will be to gradually decentralize production while raising crops and livestock in the safest, most humane regionally appropriate manner(s) possible. Two NOSB meetings a year and all the Federal Register notices in the world can’t achieve that!

Sorry to ramble and I mean no disrespect – I work in organic certification (and agriculture) every day, I purchase lots of certified organic products and have invested considerable personal energy in elevating the USDA organic standards. Organic certification is but one of many tools we have to help consumers make intelligent food choices, and like all tools it should be used properly. Using it to a task it is incapable of achieving will only break the tool and leave the task incomplete!

Mark Keating

Harriet’s response:

The organic certification process provides credibility, verification and enforcement for the organic label.

As an organic inspector, an organic consumer, and a consultant (I write transition to organic plans for the NRCS), I have found that the vast majority of people who say they are just as good as organic, but are not certified, usually have some issue that would either be a minor or major noncompliance with an organic certification agency. It could be the purchase of non-organic annual transplants at Home Depot, the use of treated seed (they think that if the cannot find untreated, then treated with prohibited synthetics is okay), or the lack of a soil-building rotation (continuous row crop or the same crop in the field without any cover cropping). I have had people tell me that Miracle Gro is allowed in organic, or that dusts are okay because they are not sprays.

Other consultants have told me the same thing—that a significant percentage of folks they work with who say they are following the organic regs, do not actually meet the letter, nor the spirit, of the organic law. The vast majority of these folks do this not out of malice, nor because they want to misrepresent themselves just to get an organic premium or make a sale. It is their ignorance of the rules and the lack of accountability to the regulation because they choose to not keep records, not keep up with the changes to the regulation, and not do their due diligence in purchasing production inputs (including livestock feeds and supplements) that results in their operations not being at the same level of integrity as their certified organic counterparts.

Understanding the organic regulation is not an easy thing, and keeping up with the changes and implementation is even more difficult. This is where the certification agencies earn their income, as well as the work they do to have all production carrying the organic label meet the same requirements.

You and I both are aware that there are numerous products that could easily mislead someone to purchase them as acceptable inputs in organic production. Without the review and oversight of an organic certification agency, they are supporting with their purchases the industrial system of agricultural production that relies on genetic engineering, synthetic inputs and abuse of our natural resources. I have also had someone tell me that since they do not use pyrethrum on their farm, they are better than all organic farmers. He thought that when something is on the National List, it meant that every farmer was using every material. I know this does not make any sense, but misunderstanding of the organic rules is both wide and deep.

So it is this credibility, verification and enforcement as well as the continuous improvement and the input from stakeholders through the National Organic Standards Board and its meetings, that lead me to say that this is the sustainable system of production. Each farm cannot decide what the word “organic” means. This would not result in a trustworthy organic label.  

Is the certification process perfect? No. Is the NOP and NOSB process the best it can be? No. Is it better than nothing? YOU BET! Can it be improved? I certainly put a lot of work into trying to make this happen, and so do others. Little by little, it is working. Is every organic farm sustainable? That depends on what your definition of sustainable is. To me, having a clear definition and expectation of what needs to be accomplished on the organic farm is very much tied to sustainability. Perhaps the sentence was not as clear as it could have been, but I do believe that the organic certification system we have does provide a sustainable path for growers and for consumers to purchase food and fiber that is environmentally responsible for both the short and long term.

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