While many components of the new Strengthening Organic Enforcement Rule (SOE) impact operations handling organic products, operations growing organic agricultural products will also experience changes. CCOF is building out resources to support our clients through the SOE implementation window. You can expect more information to reach you soon. In the meantime, here are a few things grower clients can start thinking about now.
Grower operations will need to take a closer look at the uncertified operations they use for storage. SOE requires all storage facilities handling unpacked organic products to gain certification. Only storage facilities that handle sealed, tamper-evident organic products will be allowed to remain exempt from certification. If certified products that are not in sealed, tamper-evident packaging are stored by uncertified storage facilities after the SOE implementation date of March 19, 2024, they will lose their organic status.
This change may also prompt you to evaluate how you package products. Here are a few examples of what “sealed, tamper-evident packaging” means:
- Clamshells with a sticker closing the clamshell
- Zip-top bags for produce (may have holes for air flow) with a sealed top (for example, sticker or strip that consumer must rip off to open)
- Plastic containers with film top that is fully sealed and must be ripped off to access product (container may have holes for air flow)
- Produce wrapped in plastic wrap (have to rip off plastic wrap to access item)
- Mesh bags with a label that seals the bag (must be tamper evident, for example, customer must rip open bag to access the item)
- Plastic bags tied off with stickers that would rip the bag if removed
- Produce individually wrapped in plastic with PLU label
In addition, nonretail container packaging requirements are increasing with SOE. Nonretail containers used to ship or store organic products will need to identify the product as organic and display the lot number or shipping identification to link the container to the audit trail documentation. Audit trail documentation for nonretail containers must identify the last certified operation that handled the organic product.
Finally, CCOF growers may currently work with uncertified entities to transport, broker, or export organic products. CCOF will soon be sharing resources to help you determine if these operations are affected by SOE. We recommend creating a list of these operations so you will be ready to use CCOF’s resources and take any necessary action.
Keep in mind, it takes a new applicant roughly three months to gain certification using CCOF’s normal review timelines. This timeline may extend if a wave of applications are submitted just before the deadline of March 19, 2024. If you are aware of uncertified storage facilities that will be affected by SOE, encourage them to learn more and act now! CCOF hopes to support our clients’ organic supply chains to adapt to this new rule, so we are offering a fee reduction to affected operations that apply in 2023. The discount is more advantageous the sooner the operation applies. Our applicant support team looks forward to supporting your network. We are available at getcertified@ccof.org or by calling our main line at (831) 423-2263, ext. 1.