The Organic Trade Association Supports the NOSB’s Draft Recommendation on Transitional Product
submitted by
Tom Hutcheson
Policy Coordinator
Organic Trade Association
November 2, 2001
The Organic Trade Association (OTA) supports the National Organic Standards Board’s draft recommendation on the labeling of “transitional” product. OTA’s comments on the Proposed Rule (June 12, 2000) noted:
No transitional labels are defined or recognized in the proposed rule. At least 5 States, including Louisiana, Oregon, Rhode Island, Texas, and Washington, and several private certifying agents, have regulations defining transitional certification and labeling. Those regulations vary from State to State and agent to agent. The establishment of a National Organic Program is an excellent opportunity to set a consistent national standard for the certification and labeling of transitional products. By setting a transitional standard, producers will have more incentive to convert to organic production, due to the potential for a premium price. In doing so, market forces, rather than government support payments or statutory requirements, will drive the conversion process…. [P]roducers will be required to be inspected and certified by an accredited certifying agent in order to market their products as “transitional” or “certified transitional.”
The regulatory text proposed above is consistent with Codex Guidelines, and with NOSB discussion of transitional labels (Rohnert Park, October, 1994, Sligh, p. 208).
OTA also notes that the proposal is consistent with consensus industry standards, as represented by the American Organic Standards (OTA, 1999).
Farmers making the transition to organic production must be knowledgeable and must have made a serious commitment to a new, ecologically based method of farming. USDA should provide some recognition of this preparation, as demonstrated by 12 months operation according to organic standards, so that those who have chosen to make the transition may be allowed to receive some preliminary market compensation for their commitment.
OTA thanks the NOSB for this opportunity to comment on a useful practice that was in the process of gaining recognition as an appropriate way to support farmers making the transition when the proposed and final rules were published.
