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Certification Requirements for Handling of Unpackaged Feed and Livestock

by Rachel Witte |

On January 22, 2014, the National Organic Program (NOP) published guidance 5031 “Certification Requirements for Handling Unpackaged Organic Products.” This guidance is intended to address the concern that certain products have been moving through unregulated segments of the organic marketing chain.

Effective July 22, 2015, any operations handling unpackaged organic products, including unpackaged feed and livestock, must be certified organic. The NOP guidance states that an operation is excluded from certification if it only handles organic products that are enclosed in a package or container, the products remain in the same package or container for the entire period handled, and it does not process organic products.

Examples of operations that are excluded and do not need to be certified include:

  • “Transportation companies that move certified organic hay or straw (wrapped or unwrapped) or milk from a certified organic farm to a certified organic buyer or processing facility;
  • Transportation companies that transport certified organic grain from certified operations to a certified handling facility; and
  • Transportation companies that move certified organic livestock from a certified organic farm to a certified organic slaughter facility.”

However, if an operation handles unpackaged organic products (e.g. alfalfa hay, cattle), they are not exempt and must be certified. Examples of operations that must be certified include:

  • “Operations that handle certified organic hay or straw (wrapped or unwrapped) by combining or splitting loads or lots;
  • Operations that handle unpackaged grain, including combining or splitting loads or lots, package, or otherwise handle the product other than for transport; and
  • Fruit and vegetable wholesalers that package or label containers of certified organic produce for sale as organic.”

If you are currently selling or purchasing unpackaged organic feed or organic livestock and have questions about how this guidance may affect you, please contact CCOF Livestock Supervisor Val George at If you would like information about getting your operation certified, please contact CCOF Applicant Support Specialist Jane Wade at or (831) 346-6240.