Understanding certification

Are storage and transport operators required to be certified?

To protect organic integrity, most entities in the organic supply chain require organic certification. There are limited exemptions outlined in §205.101 that do not require organic certification. Organic certification may not be required, depending on the product your operation stores or transports:

  • If you handle or store bulk, unpackaged organic products (e.g., milk, livestock, grain, etc.) or perform any other activities that may be defined as processing, certification is required. In some instances, you may be eligible to be included under a different organic operation’s certification.
  • If you transport unpackaged or bulk organic products, certification is not required for the ct of transport, provided you do not handle, process, or split lots of the product. It is required that loading and unloading of unpackaged organic products is performed by a certified organic operation.
  • If you only store or handle already packaged products that remain in the same sealed, tamper-evident container without being modified, certification may not be required.
    • Storing and distributing non-retail packaged organic products may be exempt from organic certification.
    • Selling non-retail packaged organic products requires organic certification.
    • See the OTCO Certification Matrix for more detailed information regarding allowed exemptions from organic certification.

While certification may not be required, you may choose to get certified for additional flexibility in the organic products you would be eligible to transport as well as types of actions you can take, such as refrigeration.


The USDA National Organic Program defines processing 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.

If I am not certified am I required to do any recordkeeping?

If you are under another operation’s certification, you must provide an Independent & Off-Site Storge (IS) form as well as verification that your company is allowed as an exempt uncertified operation.

Even if you are not required to be certified, as a handler of organic products you will be responsible for adhering to all regulations and protecting the integrity of organic products. This includes:

  • Prevention of commingling with non-organic products or contact with prohibited substances
  • Meeting USDA NOP organic labeling requirements
  • Demonstrate that agricultural products identified as organic were organically produced and handled
  • Maintain all organic product records for at least three years

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