My opinion of the USDA organic program after over 10 years of active involvement is pretty good. The improvements over the last 6 years with increased investment has resulted in better enforcement and management. Compared to the US record with Food Safety and spacecraft blowing up, you rarely hear about huge fraud in the organic program. This is why I am completely baffled by the failure of the USDA to address this issue for over 10 years.
You can still market an organic product under your own company name and address as the “Distributor” without being certified. There are certification agencies that will “Add” your brand to their contract manufacturers’ product list, but you will not be listed with the USDA. The big problem with this is that MANY innovative new products are contract manufactured in the organic sector. Contract manufacturing is basically a big part of the processed food industry. For some reason, it is not considered “Handling” to be responsible for product formulation, package design, marketing, selling or shipping product. Only if you actually make it are you required to be certified.
The USDA has been aware of this for many years and issued memos on certification transparency that the should cover this. Even the memo from the USDA on who needs to be certified seems pretty tough, but the practices listed above are not required activities. At least large private label operators like Trader Joe’s and Whole Foods are trying to make the certificate chain transparent by certifying their store private label products so they can be traced back to the manufacturer through the USDA Organic Integrity Website. Try looking up your Boutique Organic spread on this same website and see if they actually are certified.
Since all certified entities are required to register suppliers with the certification agency, it means organic product can be traced back through third parties in the USDA organic program. This is what creates program integrity and customer confidence. It benefits the Brand holder by being able to manage their packaging independently and allows them to provide their own organic marketing certificate to customers, instead of one in the manufacturer’s name. Brand Holder certification also benefits the consumers confidence in the organic program and your product by being able to trace the organic integrity.
The USDA once again in 2015 backed down on making brand holders get certification because certification agencies said it would cause problems for clients. Since the USDA still provide up to $750 a year to cover certification, it cannot be a huge financial burden. Why must this one small dark corner of organic certification persist after 10 years of an active program?