Keep organic strong – Make comments to the National Organic Standards Board

During the past two years, the USDA’s National Organic Program (NOP) has received significant boosts in funding to address import fraud and enforcement issues. The NOP is in the process of growing their team from 42 to 59 employees, with additional D.C. and field-based positions including new auditors, accreditation managers, and compliance and enforcement specialists. These are positive developments given that the NOP’s capacity to oversee the growing organic industry has long lagged behind growth in the marketplace.

But despite this progress, we remain deeply concerned about the future of organic.

It is more important now than ever to weigh in with the National Organic Standards Board (NOSB) on the issues that matter most to you.

You can give oral testimony to the NOSB by webinar on October 15 & 17 or in person in Pittsburgh on October 23 & 24. Sign up by October 3, 2019:

  • Webinar sign up here.

  • In person sign up here.


You can also submit written comments:

Written comments may be submitted through until 11:59 pm ET October 3, 2019.

Here are some of the topics NOC will be commenting on that we think are critically important:

1.       Import Fraud: The NOSB should continue its work to combat organic import fraud and should hold the NOP accountable in its mission to protect the livelihoods of U.S. organic farmers and the integrity of organic seal. While the NOP has increased resources and authorities to tackle this challenge, the NOSB’s continued engagement is critical to address this complex issue.

2.       Organic Dairy: The NOSB should continue to urge the USDA to issue a final rule on Origin of Livestock and to ensure compliance with the pasture rule. Without new regulations to level the playing field and strong enforcement, we will see continued consolidation within organic dairy

3.       Transparency: Each year there is a “peer review audit” conducted to assess the NOP’s program to accredit more than 80 certifiers and 50 foreign satellite offices. For the past 2 years, the NOP has failed to make public the full results from these audits, despite the requirement that they make the findings available to the NOSB and public stakeholders. Ask the NOSB to insist that the NOP provide access to the full results from the peer review audits conducted annually by American National Standards Institute (ANSI).

4.       Prohibiting GMOs: Gene editing is a form of genetic engineering that is clearly excluded in organic by definition. Express your strong opposition to any future efforts to allow products of genetic engineering into certified organic products and express support for the NOSB recommendation from 2016 to prohibit new forms of genetic engineering. The USDA still hasn’t taken action to move this recommendation forward.

5. Inerts: There needs to be a system for reviewing and identifying inert ingredients that are allowed in organic production. “Inert” ingredients frequently compose as much as 99% of pesticide products, and due to NOSB scrutiny of active ingredients they may be the most hazardous ingredients in pesticide products used in organic production. NOC recommends that the NOSB move forward with evaluating NPEs in inerts and urges the NOSB to ask the NOP to move forward quickly with implementation of the NOSB recommendations on “inert” ingredients.

We hope you will join us in protecting the integrity of the organic program by commenting to the NOSB. NOC will be submitting detailed written comments on these and other topics – please contact us if you would like more detailed talking points.

  • The NOSB proposals and discussion documents for the upcoming meeting in Pittsburgh on October 23 to 25 are available here.

  • NOC will be holding a meeting for organic leaders in Tuesday, Oct. 22 in the same location. You can learn more and register on our events page.

  • Learn more about the NOSB and their role in keeping organic strong here.


Abby Youngblood