The USDA National Organic Program’s Strengthening Organic Enforcement (SOE) Proposed Rule is a critical leap forward. It takes on concerns about fraud and promotes consistent oversight of organic products’ integrity. 

Oregon Tilth provided over 37 pages of public comment, addressing inconsistencies, identifying ambiguous language, and suggesting improvements. 

Our comments reflect a few clear goals:

• Correct issues with vague or open to interpretation language
• Eliminate administrative burden where possible, especially for certified operators
• Account for potential unintended consequences around equity and accessibility

Oregon Tilth believes SOE will help grow the sector while growing an unshakeable trust among organic supply chain participants. Without question, closing loopholes, creating unity among certifiers, fixing ambiguous standards, and increasing fraud prevention collaboration are urgent and overdue. 

We prioritize oversight and enforcement as the foundation of our work, investing in developing systems and policies that ensure certified organic businesses’ and products’ integrity. 

Here are shortcuts to Oregon Tilth’s comments by topic area: 

• Applicability and Exemptions from Certification (Excluded Handlers)
• Import certificates
• Labeling of Non-retail Containers
• On-Site Inspections (Unannounced)
• Certificates of Organic Operation
• Annual Update Requirements / Continuation of Certification
• Certifying Agent Personnel Qualifications and Training
• Oversight of Certification Activities (Certified Office Oversight)
• Foreign Conformity Assessment Systems (International Oversight)
• Compliance—General
• Noncompliance Procedure for Certified Operations
• Mediation
• Adverse Actions—General, Appeals
• Grower Group Operations (certification of)
• Calculating the Percentage of Organically Produced Ingredients
• Supply Chain Traceability and Organic Fraud Prevention