MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Mass Balance and Traceback Inspection Audits Explained

Mass Balance and Traceback Inspection Audits Explained

By Joe Pedretti

Audits are one of the tools used by organic inspectors and certification agencies to verify the USDA NOP recordkeeping and compliance requirements of §205.103 and NOP Instruction 2601 are being met.


(a) A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).”

(b) Such records must:

(1) Be adapted to the particular business that the certified operation is conducting;

(2) Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited;

(3) Be maintained for not less than 5 years beyond their creation; and

(4) Be sufficient to demonstrate compliance with the Act and the regulations in this part.

(c) The certified operation must make such records available for inspection and copying during normal business hours by authorized representatives of the Secretary, the applicable State program's governing State official, and the certifying agent.

NOP Instruction Document 2601

“8. Reconciliation of the volume of organic products produced or received with the amount

of organic products shipped, handled and/or sold, also known as trace-back audits or in/out balances;”

MOSA’s 2021 NOP accreditation audit (similar to your annual inspection) showed areas where we need to increase our verification of your recordkeeping systems. Our 2021 NOP auditors noted a need to conduct more, and more thorough inspection audits. The NOP is stressing the need for stronger, more detailed audits and the verification of recordkeeping systems, especially in preparation for upcoming changes to the organic regulations.

Audits are an important tool to prevent fraud and ensure that sufficient recordkeeping exists to verify organic integrity.

For each operation’s annual inspection a minimum of one traceback audit will be conducted.

A Trace-back Audit is used to show that an organic product can be traced back to its field of origin or supplier, using information such as lot numbers, invoices, or field activity records.

A Mass Balance (In/Out) Audit is used to show that enough organic ingredients were purchased or that crops produced, harvested, and stored coincide with your sales, or with production records of the final product. Think of a Mass Balance Audit as a weight scale; the amount of product you use or sell must match the amount of product you produce or purchase. Your inspector will look at records for a specific timeframe (for example, May through September).

Let’s look at some examples of potential records and/or recordkeeping systems that will allow an inspector to complete a successful audit:

Producer - Crops

Activity: Purchasing Seed or Seedlings

Records: Invoice/Receipt, Organic Seed Search (if applicable) and Organic Certificate

Activity: Sowing, Seeding, Transplanting

Records: Planting Log/Field Records (with dates, locations & amounts)

Activity: Harvest & Storage or Sale

Records: Harvest Log/Field Activity Records (date, location, amount), Storage Inventory Form, Sales Records (invoice, purchase order, transportation documents)

Producer - Livestock

Activity: Purchasing Feed

Records: Invoice/Receipt, Organic Certificate, Storage Inventory Form

Activity: Harvest Feed Crops

Records: Field Activity Records (harvest date, field & yield)

Activity: Feeding Animals/Grazing

Records: Daily Feeding Records,, Ration Workbook, Storage Inventory Form,


Activity: Purchasing Ingredients

Records: Ingredient Invoices, Receiving Log, Organic Certificates

Activity: Product Manufacturing

Records: Production Records (Date, Quantity, Lot Codes, Storage Records)

Activity: Packaging and Sales

Records: Invoices, Inventory Records, Transportation Records

MOSA Clients should prepare for these inspection audits by ensuring that all of the records/documentation necessary to conduct the mass balance and traceback audits are complete, accurate and available during your annual inspection. Unless otherwise instructed by MOSA, your inspector will decide which audit(s) will be used at your inspection. The audit of records can be the longest portion of your inspection and is most efficient if your records are current and complete before your inspector’s arrival.

Thank you for your dedication to organic integrity. Please contact MOSA if you have questions about audit expectations, or for recordkeeping forms and guidance.