Strengthening Organic Enforcement Rule

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The Strengthening Organic (SOE) Rule is proposed regulation put forth by the USDA NOP. The proposed changes are the most significant changes to the national organic regulations since the creation of the NOP.


The comment period for this rule closed on October 5, 2020, and the final regulation is currently under review with other USDA and Federal Government offices. After final publication, NOP has indicated there will be a one-year implementation period until all operations must comply with the new requirements.

Uncertified operations can contact today to see if you qualify for our 2022 discount! Getting certified early will ensure a seamless transition when the rule is finalized. The certification process may take up to 12 weeks and thousands of operations will need certification. Don’t wait, apply today!

Currently certified operations can expect notification of change via our newsletter.

Who will be impacted and how?

Many operations working in the organic industry will be impacted. All operations involved in organic are encouraged to review the regulations.  

Uncertified Brokers, Traders, Importers, and Brand Owners

Once implemented, SOE will require some operations that were previously exempt from certification to get certified. We encourage you to review section 1 (description begins on Page 5) of the proposed rule. Based on the draft regulations, operations that will be required to gain certification include:

  • Operations that buy and sell, or facilitate the purchase/sale of organic goods, including brokers, traders, and importers that are not currently required to gain certification.
  • Operations who act as brand owners to an organic product that is packed by a certified organic copacker. These operations will be selling organic products and therefore be required to gain a direct relationship with a certifier.

All Certified Organic Operations

  • Standardized Organic Certificates will be required, as well as more regular updating of the Organic Integrity Database by certifiers.
  • Non-retail Container labels will be required to state the organic status of products and list the certifier along with the lot number.

Certified Handler Operations

  • Operations will be required to develop monitoring practices to verify suppliers in the supply chain and organic status of products received and prevent fraud.
  • Operations that import organic products by requiring the use of NOP Import Certificates for all organic products entering the United States, even for product certified to USDA NOP standards.

Certified Grower Operations

  • Grower Group Operations – CCOF does not certify grower groups, however regulations regarding grower groups will be outlined under SOE.

There are other proposed changes that will have impacts on certifiers and certified operations. Please review USDA NOP resources for full details.


Organic Trade Association Summary of SOE Regulation
Organic Insider: Increasing Oversight Across the Organic Supply Chain
USDA NOP: Strengthening Organic Enforcement Proposed Rule
USDA NOP Flyer: Safeguarding Organic Supply Chains
USDA NOP Flyer: Am I an Exempt Retail Operation?
USDA NOP Current and Proposed Regulation Side by Side
Federal Register: Strengthening Organic Enforcement