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NOP Instruction Forces Changes for CCOF Operations

Updated May 14, 2014: On February 13, 2014, the National Organic Program (NOP) released Instruction Document 4009: Who Needs to be Certified, and accompanying Questions and Answers. This Instruction clarified what parts of CCOF-certified members’ OSPs and stages of production require independent certification. View this instruction document and the Questions and Answers document.

The NOP clarified in the new instruction that in order to strengthen NOP oversight and enforcement, contracted facilities included in a CCOF member’s OSP that process, handle, or produce CCOF member’s organic products must be independently certified. Under the instruction, CCOF-certified members that lease facilities can include the facilities in their Organic System Plan (OSP). If facilities are not owned or leased by a CCOF member, they must seek independent certification.

What You May Need To Do:

If your facility is not independently certified, and is not leased by you, but is inspected by CCOF, you can bring your production and your facility into compliance by having them complete:

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We will use existing information on file about the contracted facilities to generate their OSP and populate their certification record. New independent facilities who have existing OSPs and inspections on file will receive deeply discounted certification for only $450.

What CCOF is Doing to Help:

To comply with the new instruction, we will be implementing a 12-24 month process to identify affected CCOF members and their contracted facilities, develop solutions that meet business needs, and transition contracted facilities to certification. Because CCOF has OSPs and inspections on file for all contracted facilities, a transition to independent certification should not involve significant paperwork for those facilities and costs will be heavily discounted. We will work to develop solutions that keep low-volume, occasional-use, and reluctant contracted processing facilities in the organic program, see the Contract Partner Program below.

Certification Cost Share funds, approved in the 2014 Farm Bill, will significantly ease the effects.

CCOF will begin immediately verifying the status of all CCOF member’s and facilities included in their OSPs during inspections. If members and contracted facilities are out of compliance with the NOP Instruction 4009, CCOF will provide support to transfer the facility to independent certification.

Important Implementation Dates:

After May 1, 2014: CCOF will notify members and their contracted facilities of potential compliance issues after inspection. If you are using an uncertified facility, you will be expected to provide a corrective action plan to lease the location, facilitate the certification of the facility, or cease using it. If you are a facility being contracted by a CCOF member, you must apply for certification by submitting the Abridged Certification Application form.

After May 1, 2015: Operations using uncertified facilities and facilities handling organic products without independent certification will receive notices of noncompliance which will require corrective action. Failure to correct the noncompliance could lead to proposed suspension of the operation or affected products.

The cost of certification can be refunded using Organic Certification Cost Share.


This is counter to long-established CCOF systems for including co-packers, hullers, bottlers, or other agricultural processors in a CCOF member’s OSP, and inspecting them as part of the CCOF members’ annual inspection cycle. For many years we have allowed CCOF members to include contracted facilities in their OSPs at reduced prices, with the CCOF member taking responsibility for certification of that facility. In all cases, these facilities have been inspected and held to the same requirements as any organic processor.

Including these facilities in a CCOF member’s OSP has unintentionally resulted in the inability of the NOP to track, investigate, or inspect these operations. Organic integrity has been maintained, but the system must be modified to remain in compliance with the NOP interpretation of the standard. These contracted facilities included in a CCOF member’s OSP do not have a direct relationship with the NOP. We understand the concern of the NOP. We will work hard to implement a smooth transition that minimizes negative effects on CCOF members, meet the needs of the NOP, and comply with their mandatory instructions.

Contract Partner Program:

CCOF is committed to offering business solutions to ensure that your contracted facilities remain in the organic program. If your contracted facility is reluctant to seek independent certification, we will provide you and your contracted facilities the option to have their invoices paid by and communication directed toward you. This will allow the contracted facility to continue to operate as closely as possible to the way they were operating when they were included in your OSP. If your contracted facility enrolls in certification as your Contract Partner, they will only be charged the minimum Handler Certification Fee regardless of the value of the products they process for you. Additionally, both you and your contracted facilities’ certification fees can be refunded 75%, up to $750 via the Cost Share Program.

In order to enroll in the Contract Partner Program, the facility or service provider must fill out the Contract Partner Program Application when they apply for certification. You must sign their Contract Partner Program Application, agreeing to be an authorized contact in their OSP.