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Strengthening Organic Enforcement USDA Rule

Key Takeaways for Importers and Exporters

Certification Required

SOE requires many operations that were previously exempt from certification to now get certified. This includes importers and exporters. 

For all organic shipments to the United States, SOE requires both the U.S importer and the foreign exporter to be certified. Certification is required regardless of the product packaging.

  • Importers:
    •  If you are the importer of record for shipments into the United States, you require certification.
    • If you receive ingredients that were imported into the United States, your ingredient importer requires certification.



    • If you are the exporter of record for shipments into the United States, you require certification.
    • If your customer exports to the United States, your customer requires certification.

NOP Import Certificate Required

A NOP Import Certificate is a transaction certificate that contains detailed information about the quantity and origin of organic product being imported into the United States. Previously, this document was only required for shipments from countries where the USDA has established an equivalence arrangement. After March 19, 2024, this document is required for all organic imports, including those certified to the NOP organic standard. 

To request an NOP Import certificate, complete the CCOF NOP Import Certificate Request  and send to CCOF strives to process NOP Import Certificate Requests within 5 business days. NOP Import Certificates are billed per the CCOF Certification Services Manual. 

  1. The exporter in the foreign country will request the NOP Import Certificate from their certifier.
  2. The certifier will review the request and issue the NOP Import Certificate in the USDA Organic Integrity Database.
  3. The certifier will provide the NOP Import Certificate to the exporter, who will then provide the certificate information to the U.S. importer.
  4. Each NOP Import Certificate will have a unique identification number. As a part of its standard filing process, the U.S. importer or customs broker enters the NOP Import Certificate number into the U.S. Customs and Border Patrol (CBP) Automated Commercial Environment (ACE) system by declaring the shipment as organic, choosing the OR2 option when prompted, and entering the 21-character electronic import certificate number for each product into the field provided. This will associate the shipment details in ACE with the import certificate information. The NOP Import Certificate does not have to physically accompany the shipment, as long as the data is associated with the shipment in ACE. This process is governed by timelines determined by CBP. The NOP Import Certificate should be available for review at the importer’s organic inspection.

Key Impacts for NOP Import Certificates

  • Ensure that the import is accompanied by accurate NOP Import Certificate data.
  • Ensure products are identified as organic on all import documents including but not limited to invoices, packing lists, bills of lading, and U.S. Customs and Border Protection entry data.
  • Maintain import documents on-site and available for inspection.
  • Verify that the shipment has had no contact with prohibited substances or exposure to ionizing radiation since export. The organic importer must have a documented organic control system to conduct this verification.
  • Request the NOP Import Certificate from their certifier.
  • Identify products as organic on all export documents including but not limited to invoices, packing lists, bills of lading, and U.S. Customs and Border Protection entry data.
  • Verify that the exported product has not been exposed to a prohibited substance, treated with a prohibited substance as a result of fumigation, or treated with ionizing radiation at any point in the products’ movements across the country border.

The certifier may issue the NOP Import Certificate for a single transaction, or in certain cases may issue an NOP Import Certificate for a specific timeframe. If issued for a timeframe, the NOP Import Certificate would cover a certain amount of product shipped over that time period. The allowance for timeframe certificates can alleviate the administrative burden for operations with a high frequency of shipments, especially for fresh produce coming overland from Canada or Mexico.

Need Certification to Comply with the SOE Rule?

Contact with questions

Do you export to the United States from Canada or Mexico?

Send your NOP Import Certificate Request to Requests are processed in 5 business days

Additional Resources

For more information and updates from the USDA, visit their Electronic Organic Import Certificate website and review the Strengthening Organic Enforcement Final Rule Primer.
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