MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Certification Policy Update

Certification Policy Update

National Organic Program Final Rules

Origin of Livestock

The highly anticipated Origin of Livestock (OOL) final rule for organic dairy has been published and was effective June 6th, 2022. This change to the USDA organic regulations will promote a fairer and more competitive market for all organic dairy producers, by making sure that certified USDA organic dairy products are produced to the same consistent standard. “This action demonstrates the USDA’s strong commitment to America’s organic dairy farmers,” Agriculture Secretary Tom Vilsack said. “The Origin of Livestock final rule provides clear and uniform standards about how and when livestock may be transitioned to organic dairy production, and how transitioned animals are managed within the organic dairy system.”

MOSA is actively updating our internal policies, systems and organic plan paperwork to fully align with the new rule, which:

  • Allows a dairy livestock operation transitioning to organic, or starting a new organic farm, to transition nonorganic animals one time.
  • Prohibits organic dairies from sourcing any transitioned animals. Once a dairy is certified organic, new animals must be managed as organic from the last third of gestation. Variances may be requested by small businesses for specific scenarios.

Operations must be in full compliance by April 5th, 2023. Dairy operations can purchase transitioned animals until this date only. Any additional transitions on currently certified dairy operations must have begun before April 5, 2022 and must be complete by April 5, 2023. No additional transitions started after April 5, 2022 can be approved, except for operations not previously certified. New operations transitioning to organic can enter organic dairy two ways: by purchasing organic animals from a “last third” herd, or by transitioning nonorganic animals for one year on certified organic or third year transitional feed. Once an operation is certified organic for dairy production, all dairy animals sourced must be organic from the last third of gestation. In a few circumstances small businesses can apply for a variance from these requirements.

More detailed information about the Origin of Livestock rule is available at:


National List Updates

Fourteen ingredients and two substances have been removed from the National List. Details can be found here: National Organic Program; Amendments to the National List of Allowed and Prohibited Substances (2022 Sunset).

Two substances, Vitamin B1 (crop production §205.601) and Procaine (livestock production §205.603), must be discontinued by March 15, 2023.

The following materials have been removed from the handling National List §§205.605 and 205.606 and must be discontinued by March 15, 2024. We encourage manufacturers using any of these ingredients to source alternatives and to communicate your plan for discontinuance to MOSA.

  • Alginic acid
  • Colors (black currant juice color, blueberry juice color, carrot juice color, cherry juice color, grape juice color, paprika color, pumpkin juice color, and turmeric extract color)
  • Kelp
  • Konjac flour
  • Sweet potato starch
  • Turkish bay leaves
  • Whey protein concentrate

National Organic Program Learning Center

The National Organic Program provides a wide range of free training and outreach materials for organic farms, businesses, and organic certification agencies through their Organic Integrity Learning Center. We encourage you to explore the course offerings here:

Have you ever wondered why we verify the records we do or ask the questions we ask? One of the more recent additions - NOP-290: Organic Dairy Compliance 2 - is geared toward certifiers and inspectors, but we encourage our dairy clients to view the course as well. The presentations in this course give insight to the verification requirements that MOSA and our inspectors are expected to follow.

Organic Dairy Compliance 2 provides an in-depth review of the pasture practice standard and grazing season and pasture management requirements. The course explains the process of conducting feed audits to verify that animals receive a minimum of 30 percent dry matter intake from grazing, on average, over the course of the grazing season. It explains producer responsibilities for managing and documenting organic dairy feed.

The course provides certifier staff and inspectors with the skills needed to assess and address noncompliances related to pasture management and feed rations. It also helps certifiers understand the knowledge inspectors need to effectively assess the compliance of a dairy operation. Throughout the course, questions, interactive scenarios, and short videos illustrate situations that inspectors may encounter at a dairy operation.

Another new course offering, NOP-997: Microlearning: Evaluating the Grazing Season explains how to evaluate the grazing season according to the organic regulations.

Please let us know if you have any questions about the NOP’s training courses.