Organic Paper Chase

Suppliers and their certification agencies are sometimes their own worst enemies. There is a paranoia around certificates and products which slows down the approval process for newCert operations and products. Much of this is based on bad interpretation and choosing paper over data for a false sense of security.

Fraudulent Certificates

Suppliers are constantly telling me they do not send out certificates due to fraud. The USDA has only 18 fraudulent certificates listed on their website in the last 18 months. That is only one per month out of the over 30,000 certified operations worldwide. In only one case was the operator in the US. Most falsified certificates are from imported product.

Post your certificate on your website or customer portal and keep it updated. If a client or certification agency wants to check the validity, they can go to the USDA Organic Integrity Website or your certification agency website if they have listings. We had a client change suppliers just this week due to the difficulty in getting the certificate from the old supplier. Do not accept “Letters of Good Standing” from your certification agency. Other certification agencies no not like them and they have little standing. If you have paid and updated your information, the certification agency should not keep you from marketing properly by withholding an updated certificate. It is their duty to inspect and issue conditions. They should not hold up renewed certificates because they do not have time to inspect.

Attached Lists and Product Updates

Most organic certificates consist of a certificate face and an attached list. You need both on file from your supplier. Certification agencies are always chasing down this second page from client suppliers. The rub is, most certification agencies which issue the Certificate and Attached List as separate documents, never explain to the clients the importance of the attached list. Simple fix- issue them as one document.

The reason the Attached List(Product Listing, Product Profile) is such an issue, is the mother hen approach certification has taken. Every single product variation, package, formulation and brand representation is supposed to be approved before marketing according to the certification agency. In reality, the regulation, shown below, says only the categories need to be listed. This was verified by me with a USDA regional manager for the organic program. It is overly picky certification agencies and buyers that have driven this nanny state issue. Is it really that important if you roast organic Sumatra coffee or organic Kenya coffee?

§205.404(b) The certifying agent must issue a certificate of organic operation which specifies the:
(1) Name and address of the certified operation;
(2) Effective date of certification;
(3) Categories of organic operation, including crops, wild crops, livestock, or processed products produced by the certified operation; and
(4) Name, address, and telephone number of the certifying agent.


Operators are supposed to be “certified” to produce organic product. The basic definition of certified usually meaning being capable of doing the entire process correctly. Agreed, a lot of people never get it, but that is what the annual inspections are designed to catch. I would much prefer tougher sanctions and less reporting. My goal is to always train clients to do it correctly, not just do it for them.

It is clear this is half vent and half advice. Organic certification is already a intensely confusing process due to the vagueness of the term in general and the regulation specifically. Making it more difficult by overcompensating based on anecdotal evidence about fraud and onerous interpretations of regulation costs everyone. Suppliers and Certification Agencies should work together to make this system work for them.

About clawrence

Founder and Executive Director of AgNet Systems, Mr. Lawrence has been an executive and board member of multi-unit food service operations, non-profits and certification agencies. He entered the organic industry as a client being one of the first US producers to be certified to apply the JAS seal in the US.