Additions and Updates to Processing Certification

Additions and Updates to Organic Processing Certification

Summary: Making changes to your organic processing operation? Whether you’re adding a new facility, launching a new product, changing labels, or sourcing new ingredients, your Organic System Plan (OSP) must be updated and approved by Oregon Tilth before use. This article outlines what forms you need, when inspections apply, and how to stay compliant.

Moving or Adding a Facility

What do I need to do?

• Review your OSP to identify changes (e.g., pest management, water use, sanitation, etc.)
• Submit the required forms and facility map
• Notify us as early as possible. 4 to 6 weeks is ideal

Note: Organic certification is not transferable.

If your business is sold or merged, the new owner must re-apply and complete inspection under the new legal business entity. An inspection must occur even if the previous inspection happened less than a year ago.

Information to include:

• Equipment purchases or upgrades
• New procedures
• Facility description and layout
• Timeline for construction and startup

Required Forms:

• O1 – Operation Information (if address is changing)
• H2 – Facility Information
• H3 – Product Summary (if products or processes change)
• H5 – Sanitation and Water Practices
• H6 – Receiving, Storage, Packaging, and Shipping
• H7 – Handling Facility Pest Management
• H8 – Handling Record Keeping Practices

📌 Submit updates to your Client Services team

Will I need an inspection?

Yes. All new or relocated facilities require an inspection.

We recommend providing us with as much advance notice possible — at least four to six weeks — for scheduling and minimizing costs.

Note: Always check on turnaround times with your client services delivery team for current inspection timelines to prevent operational disruptions.

Can I process before inspection?

Sometimes. If you’re in good standing and products stay on-site, production may begin prior to inspection.

However, products processed before inspection can’t be sold or represented as organic until certification is finalized and approved.

Adding New Labels or Revising Labels

When do labels need to be submitted?

• Every time you add or revise a label
• Before printing or use

Using unapproved labels can result in:

• Lost sales
• Product recalls
• Certification suspension

We highly advise against printing unapproved labels in all circumstances.

What about bulk labels?

Templates for bulk labels may be accepted — but must be submitted and approved before use.

Can labels be pre-approved?

Yes, if you’ve submitted your OSP or a product addition, we can issue a label-only pre-approval. Keep in mind: full product compliance review is still required.

It’s possible that the review of your product, and subsequent needed changes, might require a revision to your label.

Requirements:

• Ingredients on label must match exactly with those in your Product Formulation Sheet and Master Ingredient List
• Follow guidance in our Labeling and Composition Guide

Adding a New Product to Certification

What do I need to submit?

• Labels for each product
  
  Every product addition will require you to submit all your new label(s) for each product to our team for review. Always have your labels reviewed prior to printing/manufacture.
  
  
• Master Ingredient List (MIL)
  
  Check that your supplier certificates or Non-Organic Ingredient Declarations (NOIDs) are also up-to-date in your Master Ingredient List (MIL).
  
  The certificate issue date cell in your MIL will turn orange (ingredients close to being out of date), red (ingredients out of date), or white (ingredients are current).
  
  
• Master Products List (MPL)
  
  The MPL is where you’ll add new product(s), and it should also contain all products already on your certificate.
  
  Make sure your ingredients and names match across all of your labels, certificates, and forms, such as your Product Formulation Sheet if you are required to use one.
  
  
• Product Formulation Sheet (PFS_02)
  
  Required for multi-ingredient products
  

Required Forms & Documents:

• MIL – Master Ingredient List
• MPL – Master Products List
• PFS_02 – Product Formulation Sheet
• Product Addition Process Infographic

What if my product includes non-organic ingredients?

To start, submit all non-organic ingredients to OTCO for approval prior to use, including the manufacturer’s full list of ingredients and/or processing aids that went into creating the ingredient.

You must also submit a Non-Organic Ingredient Declaration (NOID) to ensure the ingredient was not produced using organic excluded methods (with a few exceptions outlined below).

You’ll also need to submit:

• Non-Organic Ingredient Declaration (NOID)
  • This ensures the ingredient was not produced using organic excluded methods (with a few exceptions outlined below).

• Commercial Availability Form
  • If your non-organic ingredient has commercial availability restrictions… You will need to demonstrate an organic version is unavailable through the completion of a Commercial Availability Form.

• Natural Flavor Questionnaire
  • If your non-organic ingredient is a natural flavor… You must submit a Natural Flavor Questionnaire (in place of a NOID), and verify it is produced using only approved methods or following restrictions per the organic requirements. 
    
    
  • Additionally, use of non-organic natural flavors requires a Commercial Availability Form (see March 2019 Notice).

• Declaration for Nutrients, Vitamins, or Minerals (when applicable)
  • If your non-organic ingredient is a nutrient, vitamin or mineral… You will complete the Declaration for Nutrient Vitamins and Minerals in place of the NOID, as well as verification it is produced using only approved methods.

What if my product has multiple ingredients?

Submit a Product Formulation Sheet for each multi-ingredient product. If you’re using a multi-ingredient item as a single ingredient, you must obtain the manufacturer’s full ingredient list to identify what’s organic vs. non-organic.

Will this require an inspection?

• No, if the product uses existing equipment and facilities already in your certified OSP
• Yes, if using new equipment or facilities — update your OSP and schedule inspection

Planning to export?

Let us know upfront. Delays in export approval can happen if the request is made after the product is shipped.

Adding a New Ingredient or Supplier

You must update your OSP when adding new ingredients or sourcing from new suppliers to maintain traceability and compliance.

Adding a new organic ingredient

• Update your Master Ingredient List
• Submit updated supplier certificates
• Get approval before use

If using a new supplier, their certificates must be reviewed and approved by OTCO.

Adding a new non-organic ingredient

• Submit the manufacturer’s full ingredient list and processing aids
• Provide a Non-Organic Ingredient Declaration (NOID)
• If there are commercial availability restrictions, submit a Commercial Availability Form

Special ingredient requirements:

Ingredient Type	Required Form(s)
Non-organic ingredient	NOID
Natural flavor	Natural Flavor Questionnaire + Commercial Availability Form
Nutrient/vitamin/mineral	Declaration for Nutrient, Vitamin, Mineral

Required Forms:

• MIL – Master Ingredient List
• NOID – Non-Organic Ingredient Declaration
• Natural Flavor Questionnaire
• NSF ANSI 305 Commercial Availability Form
• Declaration for Nutrient, Vitamin, Mineral
• Agricultural vs Non-agricultural Determination Sheet
• Flavors Process Guide

If your ingredient will be sourced internationally, you must review our international imports policies and protocols for at-risk products.

Questions? We’re Here to Help.

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