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The following organic policy issues are open for public comment. Organic Trade Association members should lean on our regulatory staff for assistance in submitting comments, providing feedback to OTA for inclusion in our final comments, and with any issue-specific questions or concerns. 

Comment Deadline: December 18, 2017 AMS-NOP-17-0043

Interim instruction guide concerning integrity of organic imports

USDA’s Agricultural Marketing Service (AMS) is making available an interim instruction guide for organic certifying agents entitled “Maintaining the Integrity of Organic Imports (NOP 4013).” This outlines USDA organic regulations’ current requirements for certifiers engaged in the oversight of organic products imported into the United, and recommends best practices that certifiers may use to comply with existing regulations. AMS invites organic handlers, certifying agents, importers, consumers, and other interested parties to submit comments on the interim instruction. Specifically, comments should address the parts of the instruction that recommend best practices that certifiers may use to ensure compliance with the USDA organic regulations. The 60-day comment period closes on Tuesday, December 26. The Organic Trade Association's draft comments will be posted for member feedback by Monday, December 18. The interim instruction is available on the AMS website. Once finalized, the final instruction will be available in “The Program Handbook: Guidance and Instructions for Accredited Certifying Agents (ACAs) and Certified Operations.”

Comment deadline: December 31, 2017

Comments requested on Regenerative Organic Certification

The deadline for commenting on Rodale Institute’s Regenerative Organic Certification program is now December 31. NSF International is facilitating the public comment period for this certification owned by Rodale Institute. The standard’s organizers have indicated that the certification program and label do not aim to supplant current organic standards, but instead intend to build upon the USDA organic standards, particularly in the areas of labor, animal welfare and soil health. The Organic Trade Association’s Government Affairs team submitted final comments on November 1, 2017. We also encourage members to comment directly on this important topic.


Vice President of Regulatory and Technical Affairs  
(503) 798-3294
Farm Policy Director
(360) 388-6422