Recordkeeping for Processors and Handlers
What Are The Organic Record Keeping Requirements for Processors and Handlers
Summary: If you process or handle organic products, you must keep detailed and traceable records of all ingredients, sanitation practices, batch production, and sales.
These records must demonstrate compliance with USDA organic standards and be accessible during inspections. All records must be kept for at least five years and must connect each product back to its certified organic ingredients.
Why Recordkeeping Matters for Organic Processors
Strong recordkeeping is essential to maintaining your organic certification. Your system must prove that organic ingredients were properly sourced, handled, processed, stored, and shipped without contamination or commingling.
Well-maintained records support:
- Full traceability from ingredient sourcing to final sale
- Compliance with USDA organic regulations
- Fast responses to audits, inspections, or product recalls
Core Organic Recordkeeping Requirements
What records must processors and handlers keep?
You must maintain documentation that covers all major activities in your facility, including:
- Ingredient sourcing and receiving
- Sanitation practices
- Batch production and processing
- Packaging, shipping, and sales
- Inventory management
- Pest control
- Contamination and commingling prevention
Your Organic System Plan (OSP) outlines how records are managed and stored. All records must be:
- Easily accessible on-site
- Customized to fit your specific operation
- Clear, organized, and auditable
How long do I need to keep records?
You must retain all records related to organic products for at least five years.
Audit Trail Exercises for Processors
What is an audit trail?
At each annual inspection, your certifier will perform:
- Traceback exercise: Tracing a finished product back to each ingredient
- Mass balance exercise: Verifying ingredient amounts match finished product quantities
How do I prepare for audit trail reviews?
Build your system around lot code numbers — they connect each step of your operation, from purchase and receiving to production and shipping. This makes audits faster and traceability more reliable.
Inspectors will check that:
- Ingredient volumes used align with volumes produced
- Only approved inputs were used
- Records match actual practices in your facility
Sanitation & Pest Control Records
Your OSP must include sanitation and water procedures to prevent contamination.
What sanitation records must I keep?
- Cleaning logs for equipment and surfaces, especially between organic and non-organic use
- Logs for reused containers and bulk storage
- Water test results (if used in processing)
- Clean truck affidavits for all bulk/unpackaged products
- Verifies that the transportation vehicle was properly cleaned to prevent contamination from sanitizer residues or commingling with previously held non-organic products
What about cleaning and pest control materials?
Keep:
- Lists of all materials used (e.g., sanitizers, boiler chemicals, pest control products)
- Safety Data Sheets (SDS)
- Purchase receipts
- Approval status (OMRI-listed or certifier-approved)
Pest control documentation includes:
- Pest activity logs
- Prevention and extermination methods
- Requests and records for non-NOP-listed materials
Purchase Records
Ingredient purchase records verify that what you buy matches what you sell and that inputs meet organic requirements.
Required purchase documentation:
- Invoices that list ingredients as “organic”
- Organic certificates for each certified ingredient
- Spec sheets for multi-ingredient products
- Non-GMO and prohibited substance documentation for non-organic ingredients
- Supplier contact info and compliance records
Batch Production Records
Batch records verify which ingredients were used in each product and how they match your approved formulations.
Batch records must include:
- Batch numbers
- Ingredient lot codes
- Quantities used
- Cross-reference with:
- Product formulation sheet
- Master ingredient list
- Master product list
Inspectors will use batch records to ensure ingredient usage aligns with sales and that nothing unapproved was added.
Shipping & Receiving Records
Shipping and receiving logs must create a full trail of products and ingredients.
Required shipping and receiving records:
- Bills of lading with lot codes
- Receiving logs with lot codes and storage locations
- Invoices for outgoing shipments with traceable product info
Inventory Management Records
Your inventory system must demonstrate that what you produce and sell matches what you received and stored.
What to include in inventory logs:
- Ingredient amounts and lot codes
- Product quantities before sale or shipping
- Date-stamped spot checks or cycle counts
- Inventory reconciliation logs
Tips for Effective Organic Recordkeeping
- Use consistent lot codes across all documentation
- Train employees to enter data in real time
- Regularly review and reconcile records for completeness
- Keep records in a digital or physical format that is inspector-friendly
- Create standard templates or checklists for batch logs, sanitation, and inventory
Organic Recordkeeping Templates
Oregon Tilth and the USDA provide templates to help you build your recordkeeping system. Templates include:
- Ingredient and supplier logs
- Cleaning logs
- Batch production checklists
- Inventory tracking sheets
- Shipping and receiving templates
- Pest control and sanitation material logs