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Strengthening Organic Enforcement (SOE) Update for CCOF-Certified Operations

by Sarah Reed |

The March 19, 2024, compliance date for Strengthening Organic Enforcement is right around the corner. We wanted to share several things for you to think about as you plan ahead. Some of our earlier messages may have caused confusion, and we appreciate your questions.

  • Your organic certification status is not affected by the certification status of your buyers (operations you sell to). You are responsible for verifying the organic status of your suppliers (operations you buy from), if any, and operations you contract, e.g., coolers and storage facilities.
    • Even though your organic certification status will not be affected by the certification status of your buyers, supply chains could be disrupted if your buyers are not exempt and do not get certified by March 19, 2024.
    • If you co-pack for an uncertified private label brand owner, we may have asked you for information about that label owner. While you are not responsible for their certification status, we still need you to respond to those requests so that your Organic System Plan accurately reflects your activities. Please review your Compliance Report for requests specific to your operation.
  • What will happen on March 20, 2024, if I buy from or contract an uncertified operation that is no longer exempt?
    • The answer will depend on multiple factors. Does your operation have organic control systems in place? Do you have a fraud prevention program? How is your recordkeeping? Do records trace back to and include a document from the last certified handler? Has the uncertified operation applied for certification?
    • USDA National Organic Program has stated that SOE is a process, not an event. We will consider all these factors and more.
  • How do I comply with … ? When you are unclear on how to proceed, consider the “why” behind the rule, as outlined in the preamble. Propose a “how” that addresses the “why.”
    • Example: How do I label the truck transporting my unpackaged product when I don’t control the truck? Why—labeling of nonretail containers is required to protect organic integrity through the supply chain, making it clear that this is an organic product to deter fraud and prevent mistakes. How? Propose a feasible solution for your specific operational needs and address the “why.” Maybe magnetic signs are possible for your operation to implement. Maybe you have a different proposed solution that will protect organic integrity.

Please check out our SOE pages for additional resources and tools. We know it’s a lot to take in. Thank you for working with us to strengthen organic integrity!

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