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Strengthening Organic Enforcement (SOE) Changes for Nonretail Containers and Audit Trail Documentation

by kta |

Requirements for nonretail containers and audit trail documentation are changing with the new Strengthening Organic Enforcement (SOE) rule. 

  1. Nonretail containers used to ship or store organic products will need to identify the product as organic and display the lot number, shipping identification, or other unique identification that links the container to the audit trail documentation. 
  2. Audit trail documentation for nonretail containers must identify the last certified operation that handled the organic product. Audit trail documentation must identify products as organic.

Organic identification can be anything that allows someone to clearly and immediately identify the contents as organic, such as a short statement, the word “organic,” an abbreviation, an acronym, or a USDA seal. Examples may include but are not limited to “ORG,” “OG,” “O,” “MWO,” “100% OG,” or “100% ORG.” Operations may use temporary signs or labels for containers that are difficult to label due to size, shape, material, etc. 

Nonretail containers are any container used for shipping or storage of organic agricultural products. Examples include

  • produce boxes, totes, bulk containers, bulk bags, flexible bulk containers, harvest crates and bins;
  • boxes, crates, cartons, and master cases of wholesale packaged products; and
  • trailers, tanks, railcars, shipping containers, vessels, cargo holds, freighters, barges, grain elevators, silos, grain bins, or other methods of bulk transport or storage.

If a nonretail container contains retail packaged products with organic identification visible on the retail label, the nonretail container is not required to include organic identification. These include master cases, pallets, or other containers where the retail packages they hold indicate the products are organic (for example, if the USDA “Organic” seal is visible). These types of containers must still include information linking back to audit trail documentation.

Keep updated on SOE and find more details by visiting our SOE page. Nonretail containers must meet these new requirements by March 19, 2024. Send any new or updated nonretail label templates to CCOF for pre-approval before printing.

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