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Requirements for Imported Grains, Beans, Seeds, and Sugar

by Sarah Watters |

All imported products have some risk of treatment at U.S. borders and ports. Some imported products are at higher risk of being treated upon entry into the United States or have a higher risk of fraud. CCOF currently considers the following products to be high risk: sugar, grains, beans, seeds, corn, soy, edible dry beans, flax, sunflower meal, wheat, and their derivatives, imported from anywhere outside the United States.  

CCOF is implementing additional control measures for high-risk imports. For any new supplier of high-risk products, importers must provide a complete audit trail for the first shipment from the new supplier within two weeks of its arrival in the United States. Documents should identify products as organic and may include, but are not limited to, the following:

  • Chain of custody documents including shipping manifest, marine surveyor report, certificate of origin, importer of record, and exporter and domestic bills of lading.
  • Phytosanitary certificates, U.S. Customs and Border Protection clearance/entry documents (CBP forms 7501 and 3461), USDA APHIS inspection certificate, and USDA import permit.
  • Transaction certificates and/or NOP import certificates for the shipment; organic certificate for the last certified handler that produced, processed, or packaged the product; and any other known certified organic handlers in the supply chain.
  • Results from any and all residue, GE/GMO, quality, or other analytical testing performed by anyone in the supply chain.
  • Bill of lading and invoice(s) from the last certified handler in the supply chain that produced, processed, or packaged the product. Documents must show volume received.

CCOF considers the following to be importers:

  • Any operation that directly imports products or ingredients into the United States, including overseas or overland imports.
  • The first operation in the United States to receive or sell imported goods if the operation is purchasing from a certified or uncertified importer outside the United States.

If you are a CCOF-certified importer who is receiving, purchasing, transloading, or brokering high-risk products, be sure to send a complete audit trail for the first shipment from each new supplier to If you import any products, be sure to maintain audit trail documentation showing products were not treated, as all imported products have some risk of treatment.