Additions and updates to processing certification

#Move or add a facility

How do I add a new facility?

Start with a complete review of your Organic System Plan (OSP). Identify any changes you will need to make due to the facility addition or move to a new location (e.g., facility information, pest management, water and sanitation practices, etc.).

All situations are unique. It’s a good idea to contact us early in your planning process. We’ll help identify potential issues, and coordinate with our certification and inspection teams.

Here is the basic info we’ll need to get started:

  • Purchase of any new equipment
  • System upgrades or changes in procedures
  • A detailed facility description and map
  • Timeline for construction, equipment installation, records transfer, and desired production start

Depending on your planned changes, it may be necessary to submit new OSP forms to describe the new or updated practices.


Certification and certificates issued to certified operations are not transferrable to new owners in cases of mergers, acquisitions, or other transfers of ownership. In the event a business is purchased or a merger occurs, the new owner must re-apply for organic certification and complete inspection under the new legal business entity. An inspection must occur even if the previous inspection happened less than a year ago.

Which forms will I need to update?

You will need to complete the Facility Information form (H2) and document if there are any process flow changes.

Next, review your plan to look for areas you may need to update such as practices for shipping and receiving, sanitation, and pest management. Depending on what you find, you may need to update the H3, H5, H6, H7 and H8 forms.

If the address listed in your Operation Information (O1) form is closing, a new form with an updated address will need to be submitted, along with any other OSP updates related to the new address. Additionally, we’ll need notification if the certification of the previous facility location is to be surrendered

Will my facility addition require an inspection?

Yes, adding or moving to a new facility always requires an inspection.

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

Can I process product(s) at my new facility before my inspection?

An operation in good certification standing may be eligible to begin organic production prior to inspection, final review, and certification only if all products remain on site.

You must maintain the appropriate records to prove eligibility through the final review and certification of the facility. However, any pre-inspection and pre-certification production runs the risk of not being verified as organic, and will not be permitted for organic sale or representation.

#Adding new labels and label revisions


Check out our Labeling and Composition Guide to learn more about requirements that differ depending on the “organic-ness” of your product(s).

When do I need to submit labels for review?

Each time you add a new label or make changes to an existing product label, you must submit your label to OTCO for review and approval prior to use.

We advise against printing unapproved labels in all circumstances. Using a non-compliant label can result in the loss of product sales, recalls, and certification suspension.

Can I use templates for my bulk labels?

OTCO may be able to accept a label template for use and application on bulk labels, but we require that updates or new bulk label templates be submitted for review and approval prior to use.

Can I get my labels pre-approved before I am certified?

We can review and issue pre-approval of a label if you’ve submitted an Organic System Plan (OSP) or product addition for review.

Please note the approval will only verify that the label itself is compliant with the standards. A thorough review (e.g., ingredient verification, formulation, etc.) of your OSP is required to determine if the product is compliant. It’s possible that the review of your product, and subsequent needed changes, might require a revision to your label.

Can I get labels pre-approved for my new product?

Yes, we can review and issue pre-approval of a label if you’ve submitted a product addition request, but the approval will only verify the compliance of the label. Your product is still subject to review and may require a revision to your label.

What labeling requirements do I need to follow?

We’ve outlined the requirements for specific certifications in our Labeling and Composition Guide. However, in all cases, it is important to ensure that the ingredients on your label match (exactly) the ingredients listed on your Product Formulation Sheet and Master Ingredient List.

Once you finalize your label, submit it to your client service team for review and approval prior to use.

#Add a new product to certification

How do I add a product?

When adding or updating a product to your organic certification, you will be required to provide different records depending on the type of product. However, a few important guidelines apply to all product types and request scenarios.

  1. Submit your new label
    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.
  2. Update your Master Ingredient List
    Be sure to 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).
  3. Update your 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.

What if my product includes non-organic ingredients?

You must follow the same process for adding a new non-organic ingredient.

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).

  • 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.
  • 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).
  • 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?

In addition to the above requirements, you must submit a Product Formulation Sheet for all multi-ingredient products — you can read more about multi-ingredient products here.

Please note that if you use multiple-ingredient products as an ingredient, you must work with your supplier to obtain a manufacturer’s full list of ingredients and/or processing aids that demonstrates which are organic and which are non-organic (i.e., a specification sheet).

Does my product addition require an inspection?

Not all product additions require an inspection. Typically, if the new product is made using equipment, facilities, and processes that are part of your existing OSP, no additional inspection is required. However, for any product made using new equipment or facilities, you must update your OSP appropriately and an inspection will be required.

What do I need to know if my new product is for export?

If you plan to export your new product, let us know when you submit your product composition and labeling information. OTCO will then preapprove your product for export.

Waiting to request approval for exporting a product until it is already in transit may cause costly delays.


Depending on your product addition, you may find our articles on adding a label, calculating the percentage of organic content, updating your Master Ingredient List.

#Add new supplier or new ingredient

Over the lifecycle of processing your product(s), you will likely need to add a new ingredient or a new supplier of the same ingredient. We need to update your Organic System Plan to reflect proposed changes and maintain traceability of your organic products and ensure compliance throughout your supply chain.


While changing suppliers does not require an additional inspection, you will need to document, organize, and present all of your suppliers’ records at your inspection.

Adding a new *organic* ingredient

  • If your supplier is already approved…
    Update your Master Ingredient List and your supplier certificates. Submit updates to OTCO for approval prior to use to avoid potential invalidation and loss of sales in the event of any verification issues.
  • If using a new, unapproved supplier…
    Submit the supplier’s certificates to OTCO for approval prior to use in order to avoid potential invalidation and loss of sales in the event of any verification issues


Learn more about requirements for sourcing organic and allowable non-organic ingredients for your product.

Adding a new *non-organic* ingredient


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

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