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NOP 2615 OSPs, OSP Updates, and Notification of Changes Rev01 Authorized Distribution: Public

Instruction 

Organic System Plans, Organic System Plan Updates, 

and Notification of Changes

1. Purpose and Scope

This document provides instructions for USDA-accredited certifying agents (certifiers) on 

Organic System Plans (OSP). It may also help operators understand how to comply with the 

USDA organic regulations with respect to OSPs. This instruction clarifies the continuing 

certification process and explains how a certified operation may notify its certifier of changes 

that may affect its compliance with the regulations. 

The regulations require OSPs as part of all initial organic certification applications. To maintain 

certification, an operator must provide its certifier with annual updates to its OSP (see 7 CFR 

205.406), and must notify its certifier of any changes that may affect its compliance with the 

regulations (see 7 CFR 205.400(f)). Certifiers must review OSPs, annual updates, and any 

reported changes to ensure that operations can comply with the regulations. 

2. Background 

The OSP is the foundation of the organic certification process. The Preamble to the National 

Organic Program (NOP) Final Rule describes the OSP as an agreement central to certification 

that “must be negotiated, enacted, and amended through an informed dialogue between certifier 

and producer or handler and it must be responsive to the unique characteristics of each 

operation.” (See 65 FR 80558.) An operation that applies for organic certification must create a 

written OSP specific to its activities (crop production, livestock production, wild crop, or 

handling). The OSP must outline the operation’s plans for achieving and maintaining compliance 

with the regulations. The certifier must review the operation’s OSP to determine whether there is 

sufficient evidence to show that the operation complies, or may be able to comply, with the 

regulations, and the certifier must then verify the practices described in the OSP during onsite 

inspections. 

An operator seeking certification must submit an application to the certifier, typically consisting 

of an OSP and any required fees. The operator may complete the OSP using forms provided by 

the certifier, sample forms on the NOP Web site, or by submitting its own plans, procedures, 

flow charts, etc. to explain its practices and demonstrate its ability to comply with the 

regulations. The operator may also submit plans created for other government or private agencies 

in order to show evidence of its practices. For instance, a farm may submit a conservation plan 

created with the USDA Natural Resources Conservation Service to demonstrate how it maintains 

or improves natural resources. Similarly, a food processor may submit a hazard analysis and 

critical control point plan to show how it prevents the contamination of organic products by 

prohibited substances. 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 2615

Agricultural Marketing Service Room 2646-South Building Effective Date: March 20, 2024

National Organic Program Washington, DC 20250 Page 2 of 8

NOP 2615 OSPs, OSP Updates, and Notification of Changes Rev01 Authorized Distribution: Public

To continue certification, the operator must submit an annual update and certification fees to the 

certifier. The annual update must outline all changes made to the operation within the last year, 

as well as those planned for the upcoming year. In addition, if the operator makes any changes 

during the year that could affect its compliance with the regulations, it must notify its certifier. It 

is particularly important that the operation notifies its certifier immediately about the application 

of a prohibited substance, whether intentional or unintentional. 

3. Policy and Procedures

3.1. Organic System Plans

The NOP expects certifiers to require that OSPs, annual updates, and notifications of changes

contain sufficient information to determine whether an operation complies with the USDA 

organic regulations. Certifiers may not require additional information that does not relate to 

compliance with the regulations. The NOP will use accreditation assessments to verify that 

certifiers are appropriately enforcing the regulatory requirements for OSPs, annual updates, and 

notification of changes. 

3.2. Organic System Plan Overview

To become certified, an operation must complete the certifier’s application, an OSP and the 

certifier’s fees for certification review(s) and inspection(s). Certifiers must publish these fees in 

their fee schedule, which they will make available to all applicants. 

3.2.1. OSP Requirements

The OSP must address all requirements relevant to the operation identified in 7 CFR 205.200 –

205.290. The OSP includes the following areas, as applicable to the operation: 

1. A description of practices and procedures to be performed and maintained, including 

the frequency with which they will be performed. For example:

a. Practices to maintain or improve natural resources, including biodiversity;

b. Procedures for notifying neighbors and road departments to prevent 

contamination of organic crops by prohibited substances;

c. Tillage practices;

d. Cultivation practices;

e. Crop rotation practices;

f. Pest management practices;

g. Procedures for obtaining organic seeds;

h. Wild crop management practices;

i. Livestock health care practices;

j. Harvest and transportation practices including equipment cleanout to prevent 

contamination;

k. Storage practices;

l. Processing methods including equipment cleanout to prevent contamination;
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m. Labeling procedures; and/or 

n. Procedures for obtaining organic ingredients. 

2. Documentation of each substance to be used as a production or handling input. This 

should include the input’s composition and source, as well as the location(s) where 

and frequency with which it will be used. In some cases, the regulations require an 

operation using nonorganic inputs to document the commercial availability of organic 

products. For example, if a crop producer plants nonorganic seeds, then the producer 

must show evidence that an equivalent organic seed variety was not available. 

Further, some substances are only approved for specific, restricted uses. These 

restrictions can be found in the National List of Allowed and Prohibited Substances at 

7 CFR 205.601 – 205.606. The OSP must show that the substance was used in 

accordance with the current regulatory restrictions. In all cases, before using 

approved pest control substances, the operation must show that it attempted to use

adequate preventive practices first. 

Production and handling inputs may include: 

a. Soil amendments, including compost and manure; 

b. Crop production aids; 

c. Pest control inputs; 

d. Seeds; 

e. Planting stock; 

f. Livestock feed; 

g. Livestock feed additives and supplements; 

h. Livestock health care products; 

i. Post-harvest materials; 

j. Processing aids; and/or 

k. Ingredients. 

3. A description of the monitoring practices and procedures to be performed and 

maintained, including the frequency with which they will be performed, to verify that 

the plan is effectively implemented (7 CFR 205.201(a)(3)). An operation must 

monitor its activities to ensure that its organic practices are effective. The results of 

monitoring should help the operation identify areas that need improvement. This 

helps operations maintain organic integrity and maintain or improve natural 

resources. 

Monitoring methods may include:

a. Soil testing (e.g., testing for organic matter content); 

b. Monitoring soil moisture or water quality; 

c. Product quality testing; 

d. Residue testing; 

e. Monitoring crop or pasture quality; 

f. Use of body conditioning scores for monitoring herd health; 

g. Somatic cell counts; and/or 

h. Pest monitoring. 
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NOP 2615 OSPs, OSP Updates, and Notification of Changes Rev01 Authorized Distribution: Public

The description must include the monitoring practices and procedures to verify 

suppliers in the supply chain and organic status of agricultural products received, and 

to prevent organic fraud, as appropriate to the certified operation's activities, scope, 

and complexity (7 CFR 205.201(a)(3)). A fraud prevention plan must be included in 

an operation's OSP. Because fraud prevention plans must verify the organic status of 

suppliers and organic products, they should include a description of how an operation 

verifies organic status back to the last certified operation in the supply chain. For 

additional discussion of fraud prevention plans, see “Fraud Prevention Plans” in the 

Strengthening Organic Enforcement preamble at 88 FR 3603. 

4. A description of the recordkeeping system implemented to comply with 

7 CFR 205.103. 

5. A description of the management practices and physical barriers established to 

prevent contact of organic operations and products with prohibited substances. 

Operations that produce or handle both organic and nonorganic products must 

provide a description of practices and barriers to prevent commingling of these

products. 

Management practices and physical barriers may include:

a. Buffer zones to prevent contamination; 

b. Establishment of a physical barrier (e.g., a row of trees) to prevent drift of 

prohibited substances; 

c. Notification of neighbors and road departments; and/or 

d. Procedures for identifying organic products during harvest, post-harvest 

handling, shipping, processing and distribution. 

The operation’s organic certification application also includes: 

1. Applicable fees charged by the certifier; and 

2. A signed agreement or affidavit stating that the operator agrees to remain in 

compliance with the regulations, and identifying the responsible party and appropriate 

business structure as a sole proprietorship, partnership, limited liability company, 

corporation, nonprofit organization, or other structure as appropriate to the country or 

locality.

3. Additional information deemed necessary by the certifier to demonstrate compliance 

with the regulations. This may include: 

a. Name(s) of previous certifier(s) and years applied; 

b. Results of previous applications for certification; 

c. Copies of all prior Notices of Noncompliance or other adverse actions;

d. Copies of all denials of certification; 

e. A description and evidence of actions taken to correct any noncompliances; 

and/or 

f. Other information deemed necessary by the certifier. 
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NOP 2615 OSPs, OSP Updates, and Notification of Changes Rev01 Authorized Distribution: Public

3.3. Organic System Plan Annual Updates

Each year, the operation must submit to its certifier: 

1. Certification and inspection fees; 

2. Updated contact information; 

3. A summary statement, supported by documentation, detailing any changes that the 

operation made to the organic system plan submitted during the previous year (7 CFR 

205.406(a)(1)); 

4. Any changes to the previous year’s organic system plan that are planned for the 

upcoming year (7 CFR 205.406(a)(2)); and 

5. Other information deemed necessary by the certifier to demonstrate compliance with 

the regulations. 

See the Strengthening Organic Enforcement preamble (88 FR 3576) for discussion of the 

requirements for annual updates of organic system plans. 

If the operation does not submit an annual update to its certifier, then it is in violation of 

7 CFR 205.406. There are many ways to comply with this requirement. Certifiers may request 

simple written statements, modified checklists, or supplemental forms to document activities. A 

simple written statement may allow for easier compliance reviews if there are few changes.

Certifiers are to ensure organic integrity by obtaining enough information to verify compliance 

with the regulations, while being careful to set sensible limits on paperwork. Any required 

paperwork and documentation should be necessary and relevant to the applicable regulations. 

The annual update adds new information to the existing OSP. Its length and complexity will vary 

based on the type of operation. It does not require resubmission of the entire OSP or of any 

information that has not changed. Since operations are continuously certified until surrendered, 

suspended, or revoked, the annual update is not considered a new application for certification. 

Nonetheless, the update is a required and integral step in the continuation of certification process. 

For examples of the types of information the annual update should include, refer to the NOP’s 

training modules for certifiers on the NOP Web site at www.ams.usda.gov/nop or in the Organic 

Integrity Learning Center. 

3.4. Notification of Changes

The operation is to notify its certifier prior to making any changes to its OSP that may affect its

compliance with the regulations. It must demonstrate compliance with the regulations, but does

not need to report any changes that do not affect its compliance. Some examples of situations 

that would require notification to the certifier include: 

1. Application of a prohibited substance to any field, production unit, product or site 

involved in organic production or handling, regardless of whether it was a direct 

application or drift from a neighboring area, and regardless of whether or not it was 

intentional. The operation must notify the certifier immediately of any such events; 
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2. Addition of acreage, a new field, product line, production facility, animal herd, or 

animal facility to organic production; 

3. Removal of a field or portion thereof from organic production; 

4. Development of a new retail label for the operation’s organic products; 

5. New processing or handling of organic products not already specified in the OSP; and 

6. Any change in the operation’s practice, input, or procedure that may affect 

compliance with the regulations.

Refer to the NOP’s training modules for certifiers on the NOP Web site at 

www.ams.usda.gov/nop for additional examples. 

If the operation plans to add a new field, facility, production line, unique production equipment, 

animal herd, or animal facility to its certification, then the certifier will conduct an additional 

inspection before issuing an updated certificate. If the operation sells, labels, or represents 

products from fields or facilities that have not been inspected and that are not included on the 

certificate, then the operation is in violation of 7 CFR 205.100(a). Similarly, any new retail 

labels developed for the operation’s organic products must be approved by the certifier before 

being used. An operation should consult its certifier prior to using any new input in order to 

ensure that the material complies with the regulations. The use of an unapproved material may be 

considered an application of a prohibited substance, which would remove the operation’s land 

from certification for three years. 

The operation may notify its certifier of changes both verbally and in writing. The certifier 

should document all notifications so that the information may be reviewed and verified as part of 

the annual certification process. If necessary, the certifier may require the operation to submit 

additional documentation at the time of notification. Alternatively, the operation may submit 

documentation with the next annual update. The certifier will determine whether and when 

documentation is required on a case-by-case basis. 

Certifiers should clearly communicate their procedures for notification of changes to applicants 

and certified operations. The NOP will review the available evidence during accreditation 

assessments to ensure that the certifier has established appropriate requirements for being 

notified of changes. If the NOP finds that a certifier failed to enforce these requirements, or that 

a certifier required notification of changes that were not relevant to the regulations, then the NOP 

may issue a Notice of Noncompliance to the certifier. 

Certifiers may not advise operations on how to overcome barriers to certification. They should, 

however, explain the regulations so that operations can determine which types of changes could 

affect compliance, and how to notify them of changes. 

The figure below demonstrates when a notification of changes is required. 
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3.5. Certification Resources 

The NOP provides a number of certification resources on its Web site at www.ams.usda.gov/nop

and in the Organic Integrity Learning Center. The NOP Program Handbook also provides 

resources on production standards and certification procedures. 

4. References 

USDA Organic Regulations (7 CFR Part 205)

7 CFR 205.2 Terms Defined 

Certified operation. A crop or livestock production, wild-crop harvesting or handling 

operation, or portion of such operation that is certified by an accredited certifying agent 

as utilizing a system of organic production or handling as described by the Act and the 

regulations in this part.

Certifying agent. Any entity accredited by the Secretary as a certifying agent for the 

purpose of certifying a production or handling operation as a certified production or 

handling operation. 

Handler. Any person that handles agricultural products, except final retailers of 

agricultural products that do not process agricultural products. 

Could the change affect compliance? 

Yes

Determine if the change requires submission of 

records/documentation; or if the change impacts the 

operation's certification status (i.e., in the case of the 

application of a prohibited substance)

Update the operation's file with the new information, 

and/or issue an adverse action if necessary

Inform operation of impact on compliance

No

Do not require 

notification or 

updates
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NOP 2615 OSPs, OSP Updates, and Notification of Changes Rev01 Authorized Distribution: Public

Inspection. The act of examining and evaluating the production or handling operation of 

an applicant for certification or certified operation to determine compliance with the Act 

and the regulations in this part. 

Organic System Plan. A plan of management of an organic production or handling 

operation that has been agreed to by the producer or handler and the certifying agent and 

that includes written plans concerning all aspects of agricultural production or handling 

described in the Act and the regulations in subpart C of this part. 

Producer. A person who engages in the business of growing or producing food, fiber, 

feed, and other agricultural-based consumer products.

Prohibited substance: A substance the use of which in any aspect of organic production 

or handling is prohibited or not provided for in the Act or the regulations of this part. 

Records. Any information in written, visual, or electronic form that documents the 

activities undertaken by a producer, handler, or certifying agent to comply with the Act 

and regulations in this part. 

7 CFR 205.100 What has to be certified. 

7 CFR 205.103 Recordkeeping by certified operations. 

7 CFR 205.201 Organic production and handling system plan. 

7 CFR 205.400 General requirements for certification. 

7 CFR 205.406 Continuation of certification. 

Original Issue Date: December 16, 2013