MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Certification Policy Update

Certification Policy Update

By Jackie DeMinter, Certification Policy Manager

National Organic Program: Strengthening Organic Enforcement (SOE)

MOSA, and all of the operations we certify must be in compliance with the requirements of the Strengthening Organic Enforcement Rule by March 19, 2024.

Implementing these new requirements will mean some changes for MOSA as well as changes or new requirements for most operations. At MOSA, we are making updates to Organic System Plans, determining requirements for and collecting Fraud Prevention Plans, introducing the new Non-Processing Handler Organic System Plan, streamlining certification processes, and making updates to our internal processes and policies to align with the new and revised regulations. We are gearing up to begin generating certificates from the NOP’s INTEGRITY database: This will not change your certified products in any way, but your paperwork will begin to look a little different soon, and MOSA is required to report some additional information to the NOP.

MOSA is actively working toward full compliance by March 19, 2024. Continue to watch for MOSA communication about your operation’s compliance. A few things to take specific note of:

  • If you submitted your Fraud Prevention Plan (FPP) already, thank you! We will let you know if we have questions. If you have not yet submitted a FPP, submit it right away as we will otherwise be asking you to submit it as a pre-decision requirement at final review along with any other updates needed to assess compliance with the new regulations. Not getting your FPP submitted may delay us getting you your updated certificate.

  • If you ship or store agricultural products that are not for retail sale, new labeling requirements for nonretail containers may affect your operation. Operations moving nonretail containers through the supply chain must display identification of the product as organic along with the production lot number; furthermore, audit trail documentation for nonretail containers must identify the last certified operation that handled the agricultural product. The only nonretail containers that are exempt are those that are used to ship or store retail labeled products with visible organic identification. If you already use nonretail labels, be sure that your updates are submitted, approved and you have a plan for use prior to March 19, 2024.

  • Exempt handlers will need to complete MOSA’s new Exempt Handler Affidavit. This affidavit will help determine if a handler is truly exempt. Exempt operations that must complete this form may include handlers that are supplying organic product to you or those that you use in your own supply chain. All organic products must be traceable back to the last certified handler, which may be through several uncertified handlers.

The National Organic Program is continuing their work to implement the Import Certificate requirements. NOP will be providing user guides, microlearnings, and other learning resources during the SOE implementation period. Mandatory use of Import Certificates begins for all operations on March 19, 2024 – however, NOP is encouraging all exporters to begin requesting import certificates and certifiers to begin using the new Import Certificate module well in advance of the mandatory date to avoid any issues with the new module.

More information about the new strengthening organic enforcement regulation can be found on the MOSA website here:

Ion Exchange Filtration: Material Review Update

The National Organic Program issued a clarifying memo to certifiers on Ion Exchange Filtration in Organic Production. Long story short, the memo clarifies that exchange ions/recharge solutions need to be listed on the National List of Allowed and Prohibited Substances (National List), while the ion exchange resins do not need to be on the National List. If you use ion exchange filtration in your organic production, be prepared to provide additional information on the materials used in your system.

National Organic Program Organic Integrity Learning Center Updates

MOSA is encouraging our clients to stay abreast of NOP Learning Center courses. The National Organic Program (NOP) recently published a new course on livestock traceability. Traceability is key to maintaining the integrity of organic products. The new NOP-340: Livestock Traceability course gives certifiers a greater understanding of identifying livestock traceability considerations. This course focuses on the role of livestock traceability within the USDA organic control system. It introduces ways to strengthen organic integrity and identify potential fraud. The course demonstrates ways to perform organic livestock traceability at inspection and to verify handlers’ and processors’ compliance with USDA organic livestock regulations.

While this course is geared toward certifiers, it will help you understand the requirements that we are working to verify on your operation. We will maintain a heightened awareness of livestock traceability on your operation and between organic operations during our review processes.