SOE - Key Takeaways for Certified Organic Farm & Livestock Operations

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The Strengthening Organic Enforcement (SOE) Rule is regulation put forth by the USDA National Organic Program (NOP). The published rule is the most significant change to the national organic regulations since the creation of the NOP. The rule is intended to safeguard confidence in organic products and minimize fraud throughout the organic supply chain.

While its main impacts are on handlers, processors, and uncertified operations within organic supply chains, certified organic farmers are affected as well. All affected operations must meet all requirements of the rule by March 19, 2024.

Learn more with the Strengthening Organic Enforcement (SOE) Video Series.

Key Impacts on Certified Organic Grower & Livestock Operations

This summary highlights the key impacts on certified organic producers but is not meant to be comprehensive. Please review USDA NOP resources for full details.

Uncertified Storage Locations, Private Label Brand Owners, and Others

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

  • Storage facilities that store organic products that are not in sealed, tamper-evident packages or containers, 
  • Private label brand owners that buy/sell organic products that are not in sealed, tamper-evident retail packaging or containers,
  • And others.

If you are a CCOF-certified producer and you store your organic crops and/or livestock feed at uncertified storage facilities, pack into labels for uncertified private label brand owners, or work with any other uncertified operations, please review our SOE resources carefully to help determine whether these operations require certification by March 19, 2024. Please contact us with any questions. We encourage you to send this flyer, which explains the new requirements to the uncertified operations you work with, to assist them in determining whether they must get certified. 

Nonretail Container Labels

Nonretail containers used to ship or store organic products will be required to identify the product as organic and display the lot number or shipping identification to link the container to the audit trail documentation. Audit trail documentation for nonretail containers must identify the last certified operation that handled the organic product. Send all new or updated labels to for pre-approval prior to printing.

Imports into the United States

Each shipment of organic agricultural products imported into the United States must be associated with a valid NOP Import Certificate. Both the foreign exporter and the U.S. importer must get certified. If you are a CCOF-certified grower in Mexico and you export your organic crops to the United States, this requirement will also apply to you. 

To meet these requirements: 

  • You (the exporter) will be responsible for requesting the NOP Import Certificate from CCOF and providing it to your certified organic importer. 
  • The importer will be responsible for filing the NOP Import Certificate data in the U.S. Customs and Border Protection (CBP)’s Automated Commercial Environment (ACE) system. 

If you are a CCOF-certified grower in Mexico and your customer exports to the United States, they are responsible for obtaining organic certification and requesting the NOP Import Certificate from their certifier.

For additional information, visit our Import/Export webpage.

Sourcing of Livestock and/or Livestock Feed

Livestock and/or feed brokers as well as facilitators of sale, such as video auction yards, will be required to be certified to receive payment for certified organic animals and/or bulk livestock feed. If you are a CCOF-certified livestock operation and you source organic feed and/or animals from any uncertified brokers and/or facilitators of sale, please closely review all SOE information to determine whether these operations require certification by March 19, 2024. Contact us with any questions. 

Supply Chain Traceability and Organic Fraud Prevention

Operations will be required to develop monitoring practices to verify suppliers in the supply chain and organic status of products received to prevent fraud. Activities such as sourcing organic products, or sending organic products to other operations for storage, handling, or processing prior to the sale to your customer, require measures to prevent fraud or accidental representation of nonorganic products as organic.

Producer Group Operations 

CCOF does not certify producer groups (also known as grower groups), however regulations regarding producer groups are outlined under SOE.

What Next?

Please review the updated regulations and monitor communications from CCOF for important notifications and requests for information. We are here to support you in taking the steps needed to be in compliance with all the requirements of SOE by March 19, 2024. Carefully review all notifications from CCOF, respond promptly, and contact us with any questions.

Any uncertified operations you work with that require certification by March 19, 2024 can contact to see if they qualify for our 2023 discount. Getting certified early will ensure a seamless transition and our offer is most advantageous to those submitting early in 2023. The certification process may take up to 12 weeks, and thousands of operations will need certification. Don’t wait, apply today!


Be sure to check out our additional SOE resources.