Help Center
Do Brand Owners Need Organic Certification?
In many cases, yes — but there are exceptions.
The USDA National Organic Program (NOP) requires most operations in the organic supply chain to be certified. However, exemptions are allowed under §205.101.
If a brand owner hires a certified co-packer to make and label their organic product and only sells the final retail packaged goods, certification is NOT required. However, the co-packer must be certified, and the product must be listed on their organic certificate. Refer to our Help Center article Co-Packer Information.
See the OTCO Certification Matrix for more detailed information regarding allowed exemptions from organic certification.
Brand owners must be certified if they:
- Perform activities considered “processing”
- Sell or broker non-retail organic products or ingredients (including sourcing/supplying ingredients for their certified co-packer)
- Import or export organic products or ingredients
Oregon Tilth certified copackers that are packing on behalf of an uncertified brand owner must submit a complete Private Label Agreement to your Oregon Tilth client service team
Do Brokers or Traders Need Certification?
Yes. As of March 19, 2024, brokers and traders must be certified under USDA’s Strengthening Organic Enforcement (SOE) rule.
Brokers and traders include operations that:
- Buy or sell organic goods
- Facilitate sales between other certified operations
- Import/export organic goods
- Aggregate or condition product
- Store, receive, label, repackage, or otherwise handle organic products
“Handle” is broadly defined under the USDA organic regulations as “to sell, process, or package agricultural products, including but not limited to trading, facilitating sale or trade on behalf of a seller or oneself, importing to the United States, exporting for sale in the United States, combining, aggregating, culling, conditioning, treating, packing, containerizing, repackaging, labeling, storing, receiving, or loading.”
Forms & Documents
Still Not Sure?
We can help you figure out if certification is required for your business.
Contact Oregon Tilth:
📧 getcertified@tilth.org
📞 503-378-0690
🌐 Visit Forms & Documents Page