Seed and plant sourcing
#Using certified organic seed and plant stock
You are required to use organically grown seeds and planting stock. However, if the variety — or its equivalent — is not commercially available from an organic source, you may be eligible to use non-organic seed or planting stock.
Annual seedlings must be grown organically. The only approved use of non-organic annual seedlings is for re-planting in cases of natural disasters as recognized by the USDA. Seeds for sprouting must be organically grown without exception. Seeds used for edible sprout production must be organic.
Genetically engineered seeds, planting stock, and seed inoculants are prohibited from use.
#Commercial availability search
In your search for certified organic seed or planting stock, you might run into situations where there is none commercially available. When searching, you must determine if availability of an equivalent variety — seeds or planting stock with your organic system’s required growing habits, disease and insect resistance, days to maturity, etc. — may be sourced.
There is no exemption for using non-organic seed if the end product is edible sprouts. Only certified organic seed is allowed.
If not, you may be eligible to use a non-organic version. We require thorough records of your search efforts and findings. This may be a detailed phone log, printouts of emails or other correspondence with seed companies, etc. You must be prepared to provide an explanation on unmet qualities for your desired organic version of seed or planting stock.
Acceptable reasons for not finding a certified organic version:
- Not available in the appropriate form (e.g., graded, hot water treated, etc.)
- Not available in the appropriate quality (e.g., germination rate, weed seed contamination, etc.)
- Not available in the appropriate quantity (e.g., only in one ounce packets for your six acres, etc.)
All documentation concerning your seed and planting stock must be organized and kept on file with the rest of your organic records. Inadequate documentation or lack of a good faith effort to source certified organic seed could lead to a noncompliance, or disqualify a crop or land from organic certification.
#Using non-organic seed
Use — even unintended use — of seeds treated with prohibited materials will prevent certification or cause the loss existing of certification of production areas. If already certified, use will result in the loss of certified status for the crop, and removal of the impacted production area(s) from certification for three years. To avoid loss of certified status, claims of treatment due to federal or state phytosanitary regulations should be checked with your certifier prior to purchase or planting.
You may be eligible to use non-organic, untreated (e.g., no application of a prohibited substance such as a fungicide) seed to produce an organic crop if the seed is not commercially available in certified organic form, quantity, or quality sufficient to meet your needs. Cost is not an acceptable reason. Additionally, genetically engineered seeds and inoculants are prohibited.
Seeds used for edible sprout production must be organic.
You must document your commercial availability search — your unsuccessful effort to source certified organic seed from at least three trusted and reasonable sources — for review and OTCO approval.
Learn more about C-R View Dairy Farm’s best practices for seed sourcing in our Lessons Learned series on recordkeeping.
#Using non-organic plant starts
A plant start is defined as “any plant or plant tissue other than annual seedlings, but including rhizomes, shoots, leaf or stem cuttings, roots, or tubers, used in plant production or propagation.”
You may be eligible to use non-organic, untreated (e.g., no application of a prohibited substance such as a fungicide) planting stock to produce an organic crop if the planting stock is not available in certified organic form. Prior to use of eligible non-organic planting stock, you must document and submit your unsuccessful efforts to source certified organic planting stock with a commercial availability search for OTCO’s review and approval.
Perennial planting stock must be organic unless the variety you are sourcing is not commercially available. If you use non-organic planting stock, it must be organically managed for at least 12 months before any crop or part can be sold or represented as organic (e.g., planted into organic production areas). Perennial planting stock includes bramble canes (e.g., blackberries, raspberries, etc.), asparagus crowns, fruit trees, and strawberry plugs that will be left in the field for longer than a year.
Annual seedlings must be certified organic. There is no allowance within the regulations for the use of non-organic annual seedlings. The USDA has authority to grant a temporary variance due to natural disaster, research trials, or other conditions. Your certifier is required to notify you if such a variance is issued. Use of non-organic annual transplants in organic production areas will result in the crop not being eligible for organic designation, and possible removal of production areas from certification for a three-year period.
Use — even unintended use — of starts treated with prohibited materials will prevent certification or cause the loss existing of certification of production areas. If already certified, use will result in the loss of certified status for the crop, and removal of the impacted production area(s) from certification for three years. To avoid loss of certified status, claims of treatment due to federal or state phytosanitary regulations should be checked with your certifier prior to purchase or planting.
Organic products must be protected from contamination and commingling at all stages of life.
Cleaning seeds is a critical area to implement contamination prevention practices. The equipment used and complexity of cleaning and handling makes this a high-risk production area. In all cases, mixed-use equipment — machines used with non-certified organic products or prohibited materials — must be cleaned, inspected and, documented. Your process must demonstrate that non-organic seed or contaminants are not able to come into contact with organic seed when cleaning begins.
A few things to keep in mind:
- Dry cleaning — brushes, brooms, air, etc. — are all suitable techniques to ensure that non-organic contaminants have been removed
- An adequate equipment purge — organic seed run through that is diverted to non-organic sales — helps clean unreachable areas
- Clearly document your contamination prevention practices (e.g., dates, actions, photos, etc.)
- Residue testing may be required to demonstrate prevention methods are effective
Be sure to document the cleaning of equipment for annual inspection and verification. Write down the date, cleaning methods, and even take pictures for further verification that proper cleaning was done.