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

Organic Livestock and Poultry Standards - One year implementation countdown!

Look for the updated National Organic Standards and MOSA’s summary of the updates soon. When you get them, please read through the updated Livestock section (205.238 - 205.242). This rule updated the mammalian and non-avian standards (205.239), introduced a new avian standards section (205.241), and added a transportation and slaughter section (205.242).

What action do you need to take? Please review your Livestock OSP and ensure all applicable questions are answered. Our reviewers and inspectors will be assessing the new information this season. We will also be introducing a Poultry OSP for poultry operations with only outdoor access/pasture and no other organic crop or livestock production. The new OSP is a combination of the applicable areas of the Farm and Livestock OSPs. If your operation qualifies, you will be receiving this new OSP - please verify data accuracy and make updates as needed. This new option will provide a more efficient inspection and review process by highlighting information from the Farm and Livestock OSPs that is relevant to farms with only poultry production.

As a reminder, the OLPS rule is to be fully implemented by January 2, 2025 for all operations, with a few exceptions. See our last newsletter for more details. Contact us with any questions pertaining to the compliance of your operation.

Proposed Changes to the USDA Organic Regulations: Mushroom and Pet Food Standards

A proposed rule to add mushroom and pet food standards was published on March 11, 2024 with a 60 day comment period which closed May 10, 2024. The proposed changes which are based on public input and NOSB recommendations would create more consistency for these markets.

For organic mushrooms, this proposed rule would:

  • Clarify which existing crop production standards apply to organic mushroom production.

  • Create a mushroom-specific standard for organic compost production.

  • Require operations producing organic mushrooms to:
    • Use organic agricultural materials for the uncomposted portions of production substrate when commercially available.

    • Use organic spawn media when commercially available.

    • Use organic mushroom spawn when commercially available.

Pet food standards would follow the current handling standards (materials as listed on 205.605 and 205.606) and also allow materials as approved by the FDA in pet food from 205.603(d)(2) and (3) - vitamins and minerals. The proposed rule also adds Taurine to the 205.605 list for pet food.

Almost 3,400 comments were submitted! Read more about the proposed rule and view comments submitted here: Federal Register

Strengthening Organic Enforcement

The compliance date of March 19, 2024 has now passed. Do you still have loose ends to wrap up? Are you sure your supply chain is already or is actively in process to become certified? Avoid supply chain upsets by making sure you have an organic certificate from all suppliers that need to be certified.

A few things to take specific note of:

  • MOSA will soon be sending your new organic certificate from the Integrity database which will consist of the certificate page and a secondary Operation Profile. We will also continue to use the MOSA Certified Organic Products Sheet to list added details about your operation.

  • We’ll be more closely evaluating your Fraud Prevention Plan (FPP) and ensuring sufficient detail is included for your operation.

  • A reminder that all nonretail containers moving through the organic supply chain must display organic identification along with unique production lot numbering. Additionally, audit trail documentation for nonretail containers must identify the last certified operation that handled the agricultural product. Remember to update MOSA with any new labels planned for use.

  • Don’t forget to ask for the Import Certificate. If you import organic products, import certificates issued out of the Integrity Database are now required as part of your documentation.

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