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Do I Need Organic Certification? Eligibility, Exemptions, and Requirements
Summary: Most farms and businesses that grow, process, handle, or label organic products must be certified under USDA National Organic Program (NOP) standards. Some operations are exempt or excluded from certification but must still follow organic rules. If you’re unsure, Oregon Tilth’s Certification Matrix can help determine your certification needs.
Who Needs Organic Certification?
To maintain the integrity of organic products, most businesses in the organic supply chain must be certified. This includes farms, processors, handlers, and distributors.
Operations That Require Certification
If you perform any of the following with organic products, you likely need certification:
- Grow or produce organic crops or livestock
- Sell, trade, or facilitate the sale of organic products
- Process or manufacture (e.g., cooking, curing, mixing, fermenting, freezing, bottling)
- Package, repackage, or relabel
- Import organic products into the U.S.
- Export organic products to the U.S.
- Combine or condition organic products
- Store, receive, or load organic goods for sale
Labeling and Packaging Rules
Do I need certification if I apply organic labels?
Yes — if you apply a label that includes an organic claim, such as:
- The word “organic”
- The USDA organic seal
- Any other organic certification mark
If you’re only applying labels without organic claims (like pallet tags or inventory labels), certification is not required.
What if I place sealed organic products into additional packaging?
If the outer packaging includes any organic claim, certification is required. If the packaging has no organic language or seals, you do not need certification.
Optional Certification for Some Operations
When is certification optional?
Certain operations may choose to get certified but are not required to under the NOP. These include:
- Brand owners who only sell products produced and labeled by certified co-packers
- Transporters who do not handle the product beyond moving it
- Storage-only operations, depending on the nature of the activities and packaging
- Operations that meet the USDA’s exemption criteria (see next section)
Even if optional, getting certified allows you to use the USDA organic seal and make claims on your product packaging.
Do I need certification if I contract with a certified co-packer?
No. If your role is limited to selling the final, labeled product, and the certified co-packer makes the product, you do not need certification. Your co-packer must:
- Be certified
- List the products they make for you on their certificate
Who Is Exempt from Certification?
Some small or limited-scope organic operations qualify for an exemption from certification under §205.101 of the USDA Organic Regulations.
Exempt but Still Responsible
Even if exempt, your business must:
- Follow all USDA organic production and handling standards
- Prevent contamination and commingling
- Keep records for at least 3 years
- Comply with USDA organic labeling requirements for exempt products
Use Oregon Tilth’s Certification Matrix to determine whether your operation qualifies for exemption.
Prohibited Activities for Exempt Businesses
If your business is exempt, you cannot:
- Use the USDA organic seal
- Display any certifier’s seal or logo
- Represent yourself as certified
- Allow others to claim your product as a certified organic ingredient
Products Not Eligible for Organic Certification
Organic certification is only available for agricultural or agriculturally-based products.
The following cannot be certified as organic:
- Fertilizers
- Sanitizers or cleaning agents
- Pest control materials
- Soil amendments
- Minerals and salts
- Fish or aquatic species not raised under organic aquaculture rules
These materials may be reviewed for input approval (i.e., for use in organic production), but they cannot be labeled or sold as “organic.”
Summary: Do You Need Certification?
| Activity | Certification Required? |
|---|---|
| Growing or producing organic crops/livestock | ✅ Yes |
| Processing or labeling products as organic | ✅ Yes |
| Transport only (no handling or labeling) | ❌ Optional |
| Brand owner using a certified co-packer | ❌ Optional |
| Storage with no handling or labeling | ❌ May be exempt |
| Small-scale producer (exempt under §205.101) | ❌ Exempt (must follow rules) |
| Applying labels without organic claims | ❌ Not required |
| Materials like fertilizers or fish | 🚫 Not eligible for certification |
Need Help?
Still unsure if you need certification?
Use Oregon Tilth’s Certification Matrix or contact us to talk with a Certification Specialist.