The United States Department of Agriculture (USDA)'s Strengthening Organic Enforcement (SOE) Rule is now in effect, requiring both currently certified and newly impacted uncertified handlers of organic products to meet all its requirements by March 19, 2024. Aimed at combating organic fraud and safeguarding the integrity of the organic supply chain, the USDA National Organic Program (NOP) SOE rule, effective since March 20, 2023, also seeks to enhance farm-to-market traceability.
Most organizations within the organic supply chain are impacted by the SOE rule, with a projected 4,000 to 5,000 companies needing new certification. However, recent USDA NOP data shows minimal change in the number of certified organic operations over the past three months, raising concerns about compliance and potential disruptions in the organic supply chain. Many organizations previously exempt from certification now find themselves subject to the rule's requirements, underscoring the need for proactive compliance measures.
Extending Certification Requirements to Various Entities and Activities in the Organic Supply Chain
The SOE rule mandates more stringent certification practices across the organic supply chain, including importers, exporters, brokers, traders, and storage facilities that were previously exempted. Businesses involved in buying, selling, trading, or importing organic products must now hold organic certification from an independent certification body. Additionally, existing production and handling operations must adapt to the changes enforced by the new rule.
Specific activities such as combining, aggregating, culling, conditioning, treating, packing, containerizing, repackaging, labeling, storing, receiving, loading, and coffee roasting now require certification. Locations like ports of entry, grain elevators, bakeries, kitchens serving grocery chains, and warehouses are also mandated to obtain certification. Furthermore, individuals acting as freelancers in various capacities within the organic supply chain must also be certified.
Navigating Compliance Challenges and Proactive Measures for Organic Organizations
Given the complexities of the SOE rule, organizations may find it challenging to navigate compliance requirements. Engaging with an organic certification company with extensive expertise and support is recommended for faster service and processing. Additionally, organizations can benefit from utilizing a multi-assessment certification management system that streamlines both Non-GMO verification and USDA Organic certification processes.
As implementation progresses, all organic organizations need to take proactive steps. Certified organizations should conduct surveys of their organic suppliers and distribution partners to ensure compliance, while those unsure of their certification status should promptly engage with a certification provider for assessment and initiation of the compliance process. By addressing compliance requirements effectively, organizations can uphold the integrity of the organic supply chain and ensure continued consumer trust in organic products.