Are storage and transport operators required to be certified?
Organic certification may not be required, depending on the product your operation stores or transports:
- If you handle 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 provided you do not handle, process, or split lots of the product.
- If you only store or handle already packaged products that remain in the same container without being processed, certification is not required.
While certification is not 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: cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, freezing, chilling, or otherwise manufacturing, including the packaging, canning, jarring, or otherwise enclosing food in a container.
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 Storage Information Sheet.
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
- Maintenance of all organic product records for at least five years