As the global organic market continues to expand, maintaining compliance with evolving trade standards is critical to ensuring organic integrity across borders. Oregon Tilth is sharing several important international trade updates that may affect your operations beginning this fall.

Importing to the US – Reconditioning Changes (Effective October 1, 2025)

The NOP has changed their allowance on reconditioned products. Starting 10/1/2025, organic products that enter the United States without a valid NOP Import Certificate (NOPIC) may no longer be reconditioned (organic claims removed and sold on the conventional market). Products that enter the US after this date without a valid NOP Import Certificate may only be:

Reexported

• Importers who are re-exporting products must obtain & keep a copy of the Customs and Border Patrol’s (CBP) form 7512 and Export Booking Confirmation.

• The entity responsible for completing the request in the ACE (Automated Commercial Environment) System must use code 010-420-L within the ACE OR 2 message set.

Donated

• Only certified importers may choose to donate a shipment of imported products that are labeled as organic but had arrived without a valid NOPIC.

• The certified importer must maintain documentation that shows the product was donated to either a charity, nonprofit, or other similar entity. These records must be maintained and available for Oregon Tilth to review if requested.

• The entity responsible for completing the request in the ACE (Automated Commercial Environment) System must use code 010-420-L within the ACE OR 2 message set.

Destroyed

• Importers who choose to destroy the shipment must obtain and maintain a copy of CPB’s Certificate of Destruction.

• The entity responsible for completing the request in the ACE (Automated Commercial Environment) System must use code 010-420-L within the ACE OR 2 message set.

Please note, the entity responsible for filing with the ACE system may be the importer or may be an exempt operation such as a Customs Broker.

For more information, please refer to NOP’s SOE Frequently Asked Questions: Organic Imports.

Chilean Transaction Certificate Retired

Oregon Tilth has retired our Chilean Transaction Certificate. Please use our OTCO Transaction Certificate instead if you are exporting organic goods to Chile. Keep in mind that OTCO only assesses compliance with the NOP, LPO, and EU regulations. It is up to your operation to ensure you comply with all other regulations for the destination country.

Japan – Livestock Feed

Oregon Tilth has received confirmation that specific livestock feed products may be exported to Japan under the US/Japan Equivalency if the following criteria are met:

• Single Ingredient products
  • Such as organic hay, organic corn, organic soybeans, etc.
  • Multi Ingredient livestock feed products
    • IF the organic content of the product is at or above 95%. 
    • Note, this is a change from typical organic livestock feed certification for the NOP.
    • Contact your client service team if you have any questions.

European Union – Organic Pet Food

The European Union (EU) has developed organic standards for pet food. Oregon Tilth can now assess if your organic pet food products meet the terms of the US/EU trade arrangement. Organic pet food products must contain at least 95% of organic ingredients. Contact your client service team if you have any questions.

TRACES (European Union, Switzerland, Northern Ireland) – Effective October 16, 2025

The European Union’s TRACES (Trade Control and Expert System) has added additional operator profile requirements based on the activities the operator performs. If your company is listed on the EU COI (Certificate of Inspection), your operation is required to have a TRACES account with the correct activities listed. Below is a list of the required activities based on the boxes on the EU COI:

Box 4: “Producer or processor of the product”

• If you produce or prepare the product exported, please add “organic production” and/or “organic preparation”. The EU defines these terms as follows:
  • Organic production (EU 2018/848 Article 3 (1)) means the use of production methods that comply with the (EU) regulations at all states of production, preparation, and distribution
  • Organic Preparation (EU 2018/848 Article 3 (44) means:
    • the operations of preserving or processing of organic products, or
    • any other operation that is carried out on an unprocessed product without altering the initial product, such as slaughtering, cutting, cleaning, or milling
    • packaging, labeling, or alterations made to the labelling relating to organic production

Box 5: “Exporter”

• If you export the product, please add “organic exporting” and “organic preparation”

Box 6: “Operator who buys or sells the product without storing or physically handling the product”

• If you distribute your product without storing or physically handling the product, please add “organic distribution”

For more information on how to add additional activities, please refer to the TRACES Getting Started: Add Activity website. Once you have requested the appropriate activities, OTCO will verify your request.

US/EU Equivalency: Reminders for US based brokers/traders.

There has been increased focus by the European Union on US based brokers and traders. As a reminder, the US/EU equivalency is limited to direct trade between the US and the European Union.

Products must be produced or have final processing occur within the US or EU to qualify. Operators who handle (buy, sell, trade, etc.) products from third countries that never enter the US or EU for final processing are not eligible to operate under the US/EU equivalency arrangement.

Similar to the NOP, the EU requires that operators at all stages of production must comply with the EU regulations, this includes import, export, and sale. OTCO is not able to offer EU certification to US based operations per EU 2021/1378 Article 2(1)(c) as the US is covered under an equivalency arrangement with the EU.

Because the United States has an equivalence arrangement with the EU, the European Commission has decided it will not allow EU 2018/848 certification of any US-based operators, including traders and brokers.

If your operation is involved in any stage of production as defined by EU 20218/848 Article 3(50), you are responsible for complying with the EU regulations.

Japan – Organic Alcohol Now Covered Under the US/Japan Equivalency Arrangement (Effective October 1, 2025)

Alcohol is now included in the US/Japan Equivalency Arrangement (JAS). JAS-certified alcoholic beverages produced and packaged in Japan can be sold as “organic” in the U.S., except wines containing non-National List synthetic sulfites. NOP-certified alcohol produced and packaged in the U.S. can be exported to Japan but must be labeled with the JAS seal by a JAS-certified importer. Because Japan does not recognize a “made with organic” claim but allows synthetic sulfites in JAS-organic wine, U.S. “made with organic” wine  may be exported to Japan labeled as “organic,” but such labels must be designated “for export only.”

NOP Import Certificates – Multi-Shipment Policy Update

OTCO has changed our policy when issuing NOP Import Certificates (NOPICs) for multiple shipments to be in alignment with the NOP’s SOE FAQ. Going forward, clients requesting NOPICs that cover multiple shipments must provide at least one shipment identification on the NOPIC. This may include lot numbers, batch numbers, container numbers, etc. OTCO is in the process of updating our NOP Import Certificate form and request instructions.

Operations that request multi-shipments covered under NOPICs must have a method to link any additional shipments to the NOPIC.

As a reminder, each NOPIC covers a commodity or a HTS code. If you are exporting different products with different HTS codes, individual NOPICs are required.

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Oregon Tilth helps certified operations navigate evolving international trade requirements. We appreciate your attention to these updates and your continued commitment to upholding organic integrity.

If you have any questions about these updates, please contact your Client Services Team for assistance.