On December 2, 2019, Oregon Tilth provided public comment to the USDA National Organic Program (NOP) on the Origin of Livestock proposed rule change.

We support continued efforts to ensure strong, consistent standards for organic dairy production; this is critical to maintaining credibility, improving transparency, and ensuring a level playing field for all certified operations. We urge swift finalization of the rule and implementation effective immediately upon publishing, with the only exception being for currently certified producers with animals in transition being allowed to complete the transition as approved by their certifier.

Oregon Tilth’s approach to the origin of livestock in regards to dairy animals is already in line with the current proposed rule, and we hold all our operations, of all sizes, to the same requirements. As such, once the final rule is published, our certified operations will feel very little effect, apart from the assurance that all other organic dairy operations are being held to the same standard. Overall, this proposed rule will be of great benefit to the organic dairy industry and again we urge swift finalization and immediate implementation.

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