The Strengthening Organic Enforcement rule requires that all organic imports to the United States are associated with a valid NOP Import Certificate. Shipments that arrive in the United States without a NOP Import Certificate may not be sold as organic in the United States. Previously, certified importers had the option to recondition the product. Reconditioning is the process of relabeling and reinvoicing the product to remove all organic claims.
Effective October 1, 2025, reconditioning will not be allowed for shipments arriving in the United States without a valid NOP Import Certificate. Certified importers may only re-export, donate, or destroy products without a valid NOP Import Certificate. Uncertified importers may only re-export or destroy these products.
For more information, please see the NOP Notice below and look for updates to the Strengthening Organic Enforcement FAQs: https://www.ams.usda.gov/rules-regulations/strengthening-organic-enforcement/faq
Change in Reconditioning Procedures for Organic Shipments Entering the United States Without a National Organic Program Import Certificate (NOPIC)
Effective October 1, 2025, importers may not recondition certified organic shipments that arrive in the United States without a valid National Organic Program Import Certificate (NOPIC). Accordingly, any organic shipment that arrives in the United States after October 1st without a valid NOPIC will be subject to immediate re-export, donation (with restrictions), or destruction as follows:
Re-export:
For importers re-exporting a shipment labeled as organic that arrives without a valid NOPIC, the importer must retain a copy of the CBP 7512 form and Export Booking Confirmation, to be provided to the importer’s certifier (if applicable), and USDA upon request. The Customs broker/filer will still need to use code 010-420-L within the ACE OR 2 message set.
Donation:
Only certified importers may choose to donate a shipment of imported products that is labeled as organic but arrives without a valid NOPIC. The donation option is not available to an uncertified importer. The importer must provide documentation that the shipment was donated to a charity, nonprofit, or other similar entity to the importer’s certifier. The importer must maintain the documentation in an electronic format and provide it to USDA upon request. The Customs broker/filer will still need to use code 010-420-L within the ACE OR 2 message set.
Destruction:
Importers can choose to destroy the shipment. The importer must obtain an official CBP Certificate of Destruction, maintain the Certificate in an electronic format, and provide it to USDA upon request. If the importer is certified, the importer must provide the Certificate of Destruction to its certifier. The Customs broker/filer will still need to use code 010-420-L within the ACE OR 2 message set.
