Organic Certification for Storage and Transport Operators
Organic Certification for Storage and Transport Operators
Summary: If you store or transport organic products, whether you need certification depends on the product type and your activities. Handling bulk or unpackaged products typically requires certification. Storing sealed retail packages or transporting bulk products without processing may be exempt. Even if you’re exempt, you must still protect organic integrity and follow all record keeping and labeling rules.
Do Storage and Transport Operators Need Organic Certification?
It depends on what you store or transport, and how you handle it.
The USDA National Organic Program (NOP) requires most operations in the organic supply chain to be certified. However, exemptions are allowed under §205.101.
Use the guide below to determine if certification is required for your storage or transportation operation.
When Certification Is Required
You must be certified if:
- You store or handle unpackaged or bulk organic products (e.g., milk, grain, produce, livestock)
- You perform activities considered \”processing\”, including splitting shipments, repackaging, relabeling, or reconditioning
- You sell organic products that are not in retail-ready packaging
If your facility performs loading/unloading of bulk organic goods, this also must be done by a certified operation.
When Certification May Not Be Required
You may be exempt from certification if:
- You only store or handle packaged organic products that are:
- Fully sealed
- Labeled for retail sale
- Unmodified while in your control
- You transport bulk or packaged organic goods but do not:
- Process
- Open containers
- Split lots
- Relabel or repackage products
Note: If you’re storing non-retail packaged products but not selling them, you may still be exempt. However, if you sell those non-retail packages, certification is required.
See the OTCO Certification Matrix for more detailed information regarding allowed exemptions from organic certification.
Should I Choose Certification Even If It’s Not Required?
Yes — in some cases, voluntary certification is beneficial.
Getting certified may allow you to:
- Handle a wider range of organic products, including bulk or non-retail packages
- Offer value-added services, like refrigerated storage
- Avoid limitations when working with certified partners
- Reduce compliance risk by having your own certification oversight
What If I’m Covered Under Another Operation’s Certification?
If you are a third-party storage provider or off-site warehouse working under another company’s organic certification, you are still required to:
- Complete and submit the IS – Independent Off-Site Storage form
- Be listed as an approved, uncertified handler in their Organic System Plan
- Keep detailed records of all organic products handled
Even if I’m Not Certified, What Are My Responsibilities?
Whether certified or exempt, you are responsible for protecting organic integrity throughout storage or transportation.
You must:
- Prevent commingling of organic and non-organic products
- Avoid contamination with prohibited substances
- Ensure NOP-compliant labeling on all organic goods
- Keep all records related to organic products for at least three years
- Demonstrate traceability of every organic product handled
What Is Considered “Processing” by the USDA?
According to the USDA NOP, processing includes (but is not limited to):
“To sell, process, or package agricultural products, including but not limited to trading, facilitating sale or trade, importing or exporting, combining, aggregating, culling, conditioning, treating, packing, containerizing, repackaging, labeling, storing, receiving, or loading.”
If you perform any of these activities, you likely need certification.
Summary: Do I Need Organic Certification?
| Activity | Certification Required? |
|---|---|
| Store sealed, retail-packaged products | No |
| Store bulk or unpackaged products | Yes |
| Transport sealed retail products only | No |
| Transport bulk products (no handling) | No, if no handling or processing |
| Load/unload bulk products | Yes, must be done by a certified operator |
| Sell non-retail packaged products | Yes |
| Store under another certified operation | No, but IS form is required |
Required Forms & Documents
📄 IS – Independent Off-Site Storage (Download & Submit)
Submit to your Oregon Tilth client service team to confirm your exemption or inclusion under another operation’s certification.
Need Help Determining Certification?
We’re here to help you understand your role in organic compliance.
Contact Oregon Tilth:
📧 certification@tilth.org
📞 503-378-0690
📄 Visit Forms & Documents Page