Brand owners, marketers, and brokers

#Understanding certification

Organic certification may not be required, depending on the product your operation stores or transports.

Operations that only handle packaged organic products, which remain in the same package or container are not required to be certified. You are prohibited from opening or re-labeling organic products. Certification for brand owners, marketers, and brokers/traders — with the exception of livestock brokers — is optional.


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, and maintenance of all organic product records for at least three years (five for certified operations)

Brand owners and marketers
Even if certification is not required, you may choose to get certified to:

  • Use one certifier on labels. Certification allows you work with multiple facilities with different certifiers and label your product with your own single label and certifier designation (pending review and approval).
  • Ownership of an organic certificate. In addition to direct engagement with the certifier — not going through your co-packer for approvals of labels, formulations, etc.— you will have direct oversight of your organic supply chain, not through a third-party co-packer. Your co-packer’s certifier will still need to review records and documentation, but it has been vetted and approved — the result is a more efficient process.

Brokers and traders
Operations that buy and sell goods, brokers and traders, will also occasionally take physical possession of products or simply facilitate the movement of the products. Even if certification is not required, you may choose to get certified to be competitive or protect supply chain information.

Application for certification

If you are a brand owner, broker, marketer, or trader and want to pursue organic certification reach out to us at <> to get started.

#Using a co-packer

A co-packer — also known as a co-manufacturer — processes products for different companies based on individual specifications and can vary in size and scope. Co-packers provide services such as ingredient sourcing, packaging, labeling, manufacturing, product development and distribution.

Only operations that physically manufacture, process, package/re-pack, or label/re-label organic products are required to obtain organic certification. If you contract someone else to produce organic products for you, and only sell the finished packaged and labeled product, you do not require certification. Your co-packer or custom manufacturer is required to be certified.

Labels for USDA National Organic Program certified products must identify the handler and the certifier on the ingredient panel. If your label states “Certified organic by Oregon Tilth” below your handler information — and the handler is not certified by OTCO — you will need a Private Label Agreement.


As an uncertified brand owner, even if your label says “Certified organic by Oregon Tilth,” that does not mean you are certified, or that you can take your product to a separate manufacturer and use the same label without submitting labels to their certifier for compliance.

Forms & Documents

Download the above and submit it to your client service team.


As part of the organic certification process, an annual on-site inspection is required.

At inspection, you’ll need to clearly demonstrate the organic integrity of your product throughout its lifecycle. We will perform a thorough audit of your documentation records. For new applicants, your initial inspection will verify that your Organic System Plan (OSP) is in alignment with all proposed activities. For currently certified clients, the annual inspection will verify that your operation is meeting all prescribed activities per your OSP.


Inspections for brand owners are primarily focused on recordkeeping and documentation practices. You must be accessible at the listed address on your organic certificate, whether working from a home office or business address.

Audit trail
During your inspection, your inspector will review records to ensure that your organic product was produced without prohibited materials, used only the listed organic ingredients, prevented commingling and contamination, and more. In addition, the inspector will conduct audit exercises, including an “in-out balance” audit, to ensure that the amount of ingredients purchased corresponds to the amount of product created.

Learn more about audit trail exercises, examples of records inspected, and additional questions in our inspection FAQs.


You must maintain well-organized, accessible records that date back at least five years from the creation date for each organic product.

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