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Instruction

Accreditation Policies and Procedures

1. Purpose and Scope

This instruction provides general policies and procedures for organizations seeking accreditation 

to the U.S. Department of Agriculture (USDA) organic regulations, which are administered by 

the National Organic Program (NOP). Organizations that are accredited are called accredited 

certifying agents, or certifiers. The NOP Accreditation Division applies policies and procedures 

to determine and maintain certifier accreditation. This instruction applies to U.S. and foreign 

organizations who wish to obtain, maintain, or renew accreditation. In 2023, the Strengthening 

Organic Enforcement final rule (88 FR 3548) updated many sections of the organic regulations, 

including the requirements for accreditation.

2. Responsibilities

2.1 AMS Administrator

The AMS Administrator is responsible for executing the USDA organic regulations and making 

final appeals decisions affecting certifiers and certified operations located in States without 

established State Organic Programs. 

2.2 NOP Deputy Administrator

The NOP Deputy Administrator is responsible for accrediting and assessing certifiers, providing 

guidance and training to certifiers, and reinstating suspended accreditations. The Deputy 

Administrator may assign specific tasks related to these activities to qualified NOP personnel but 

retains final responsibility for their proper execution.

2.3 Accreditation Division (AD)

The AD is responsible for administering the NOP’s accreditation activities. These activities 

include, but are not limited to:

a. Determining, planning and managing audits of certifiers and applicants for accreditation;

b. Directing Accreditation Committee activities pursuant to NOP 2012 Accreditation 

Committee Instruction;

c. Recommending accreditation, suspension, or revocation of certifiers to the NOP Deputy 

Administrator;

d. Notifying applicants for certification of accreditation decisions; and

e. Making publicly available all certifiers’ current accreditation statuses.
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The AD Director may delegate specific tasks related to these activities to qualified NOP 

personnel, other AMS Programs, or qualified State or private organizations, but retains final 

responsibility for their proper execution.

2.4 Accreditation Committee

The Accreditation Committee reviews new and renewal accreditation applications as well as 

other select decisions, including, but not limited to, corrective actions, scope expansion or 

reduction, and proposed suspensions and revocations. The Accreditation Committee prepares 

recommendations to the NOP Deputy Administrator for final accreditation decisions.

The Accreditation Committee is comprised of NOP personnel who have experience with 

applying the USDA organic regulations, agricultural production and processing practices, and/or 

evaluating audit-based certification programs.

2.5 Auditors

Auditors conduct accreditation audits under the direction of the AD Director. Auditor 

responsibilities include:

a. Planning, conducting and reporting the results of pre-onsite quality manual audits (desk 

audits);

b. Planning, conducting, and reporting the results of pre-decisional, mid-term, and renewal 

audits, and notifying applicants for accreditation in advance of the names of the audit

team members, to allow any certifier to object to the appointment of any team member;

c. Providing audit estimates based on published hourly user fees and travel expenses for 

accreditation-related services provided by the NOP; and

d. Other duties as determined appropriate by the AD.

2.6 Certifiers

Certifiers are responsible for:

a. Meeting the applicable requirements of the USDA organic regulations;

b. Providing access to information, documents, and records as necessary for the audit and 

maintenance of accreditation;

c. Providing access to documents that provide insight into a certifier’s level of 

independence and impartiality from its related bodies, where applicable;

d. Arranging witness and/or review audits and operational visits of certified operations or 

applicants as requested by the NOP or authorized auditors; and

e. Attending required NOP trainings.

3. Accreditation Process

This section outlines the accreditation procedures for applicants for accreditation and certifiers 

that certify organic operations pursuant to the USDA organic regulations.
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3.1 Eligibility

Accreditation services are available regardless of the number of certifications to be issued by an 

applicant for accreditation. Accreditation is not conditioned on the number of certifications 

issued, agency size, or membership in any association.

a. Nondiscrimination 

USDA prohibits discrimination on the bases of race, color, religion, sex, age, national origin, 

marital status, sexual orientation, familial status, disability, limited English proficiency, or 

because all or a part of an individual’s income is derived from a public assistance program.

Persons with disabilities who require alternative means for communication of program 

information (Braille, large print, audio tape, etc.) should contact USDA’s TARGET Center at 

(202) 720-2600 or (844) 433-2774 (toll-free nationwide). To file a complaint of discrimination, 

write to USDA, Director, Center for Civil Rights Enforcement, 1400 Independence Avenue SW,

Washington, DC 20250-9410, or call (202) 632-9992. USDA is an equal opportunity service 

provider and employer.

b. Travel restrictions

NOP accreditation is not available to certifiers that are based only in or conduct key activities in 

areas where the U.S. Department of State has issued travel warnings, travel alerts, or other 

restrictions that could affect the health, safety, or security of Federal employees. Applicants for 

accreditation that are affected by such warnings, alerts, or restrictions will be denied 

consideration and have their applications and fees returned. 

If an audit of a certifier cannot be conducted as required by the regulations due to U.S. 

Department of State travel warnings, travel alerts, or other restrictions, the NOP may suspend the 

certifier’s accreditation until conditions change and/or restrictions are lifted. The NOP will 

explore alternative methods for conducting audits but if no viable alternatives exist, accreditation 

will be suspended. 

c. Accreditation Audit Cycle of Certifiers

Table 1 below illustrates the type and frequency of AD accreditation audits during the five-year 

accreditation cycle. Actual timeframes during which the audits occur may differ based on the 

certifier’s previous audit. Renewal audits are conducted as close as possible to the five-year 

accreditation anniversary date.
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Table 1 – Audit Cycle

Application Stage Initial 5-Year Cycle Subsequent 5-Year 

Cycles

0-3 months:

Documentation 

adequacy review

3-9 months:

Pre-decisional 

audit

0-24 months: 

Initial audit

24-36 months: 

Mid-term audit

54–72 months: 

Renewal audit

54–72 months: 

Renewal audit

4. Accreditation Applications

Initial accreditation applicants and certifiers seeking accreditation renewal must submit an 

application package to the AD according to procedures described below. 

4.1 Application Package 

The application package must be submitted in English, and must include: 

a. All supporting documents and procedures required by §§ 205.503-505,

1 and fees required 

by § 205.640; 

b. A signed copy of TM-10CG Application for Accreditation; 

c. A signed copy of LPS-109 Application for Service; and 

d. A $500 application fee in the form of a check or money order made payable to “AMS.” 

Contact the NOP for submission of electronic payments.

Submit the application package to AIAInbox@ams.usda.gov. 

Contact the NOP for instructions on submitting electronic documents to an approved USDA 

cloud computing system. 

If the application cannot be submitted electronically, it may be submitted to: 

USDA, AMS, National Organic Program 

c/o NOP Accreditation Division

1400 Independence Avenue, SW 

Room 2648, Mail Stop 0268 

Washington, DC 20250 

Email: AIAInbox@usda.gov

1 Section 205.503(e) includes countries where operations are certified through cooperative agreements and inspections are contracted with other 

certifiers.
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4.2 Renewal Application Planning

Certifiers must renew their accreditation or surrender their certificate of accreditation pursuant to 

§ 205.510 of the regulations. Certifiers must apply to renew their accreditations 1 year to 6 

months prior to the anniversary date of their accreditation period, or risk a lapse in their 

accreditation.

4.3 Processing Applications

The AD reviews all initial and renewal applications to determine whether all the required 

information was submitted, and whether the applicant is affected by any of the travel restrictions 

described in Section 3.1 above. The NOP will notify the applicant whether the application is 

accepted or denied. If it is accepted, it will be referred to auditors to conduct a document 

adequacy review.

4.4 Accepted Applications

The objective of the documentation adequacy review is to evaluate the applicant or certifier’s 

documented quality manual’s compliance with the Organic Foods Production Act of 1990, as 

amended (OFPA), the USDA organic regulations, the National Organic Program Handbook, and 

any other identified requirements. The review is conducted before an onsite audit. Its scope is 

based on the scope of each audit. 

The documentation adequacy review for initial and renewal applications is conducted as follows:

a. The AD Director selects and assigns auditors to conduct the review. The auditors may 

request additional information from the applicant. The applicant must respond to an 

auditor’s request for additional information within the designated timeframe. All auditor 

requests must be adequately addressed for the applicant to be further considered for 

accreditation.

i. If the applicant does not respond, or submits inadequate information, the auditor will 

notify the AD Director that they are unable to complete the review due to insufficient 

information. The AD will then send the applicant a Notice of Denial of Accreditation 

citing § 205.502 as the reason, and stating that the review has been discontinued due 

to insufficient or inadequate information. 

ii. For initial applicants, the auditor will complete the review and submit a report for 

review within 90 days of receipt of the application package. The AD Director will 

review the report for content and clarity, and will contact the auditor for clarifications 

if necessary. Based on the results of the review, a pre-decisional onsite audit, or 

renewal audit, as applicable, will be scheduled. Or, denial of accreditation will be 

issued.

iii. For renewal applicants, the auditor will schedule an onsite audit and present all 

findings to the renewal applicant at the completion of the onsite audit. 

5. Types of Onsite Accreditation Audits 
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5.1 Pre-decisional Audit

a. A pre-decisional audit is conducted within six months of completion of the document 

adequacy review to determine if the applicant is capable of complying with the OFPA 

and USDA organic regulations.

b. The audit team reviews key activities, conducts witness and review audits, interviews 

certification personnel, and reviews certification files.

c. This audit is conducted in accordance with the procedures described in this instruction.

d. Accreditation may be granted as a result of the pre-decisional audit. If granted, AMS will 

issue the accreditation certificate at this time.

5.2 Initial Audit

a. After accreditation is granted, an initial audit is conducted to determine if the certifier is 

complying with the audit criteria and has the competence required by the audit criteria

scope. The initial audit also verifies the implementation and effectiveness of any 

corrective actions. It includes a review of the certifier’s key activities, witness audits, 

review audits, certification personnel interviews, and certification file reviews.

b. The initial audit is conducted within two years of the date of accreditation during the 

initial five-year accreditation cycle (see Table 1).

5.3 Mid-term Audit

a. At the mid-term audit, the audit team reviews the certifier’s key activities, verifies the 

implementation and effectiveness of corrective actions, conducts witness audits and 

review audits, interviews certification personnel, reviews certification files, and conducts

any other activity as directed by the AD.

b. A mid-term audit is normally conducted between 24 and 36 months from the date of 

accreditation or accreditation renewal.

c. This audit is conducted in accordance with the procedures described in this instruction.

5.4 Renewal Audit

a. The renewal audit is conducted to determine if the certifier is complying with the 

regulations, to verify the implementation and effectiveness of any corrective actions

taken, and to determine whether the certifier has maintained the competence required by 

the regulations.

b. The renewal audit is conducted between 6 months before and 12 months after the 

anniversary date of the certifier’s accreditation.

c. This audit is conducted in accordance with the procedures described in this instruction.
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5.5 Audit Planning Guide

The Audit Planning Guide in Table 2 may be used as a tool to estimate the number of days to 

complete an audit. The presence of additional auditors may decrease the audit time. 

Table 2 – Audit Planning Guide

Standard Duration (days) Total

Pre-Onsite 2

Onsite 2

Witness inspection 

and/or review audits

1

Time Increase Factors

Number of countries 

with certified 

operations

1 additional countries

+ 0 days + 1 day per country

Number of certified 

operations

< 100 100-1000 > 1000

+ 0 days + 1 day + 2 days

TOTAL DAYS

Number of auditors 1 1 -2 2

Example:

Certifier has:

• 4 countries where certified operations are located

• 1,500 operations 

Audit Planning Guide- Example

Standard Duration (days) Total

Pre-Onsite 2 2

Onsite 2 2

Witness audit and/or 

review audits

1 1

Time Increase Factors

Number of countries 

with certified 

operations

1 additional countries 4

+ 0 days + 1 day per country

Number of certified 

operations

< 100 100-1000 > 1000 2

+ 0 days + 1 day + 2 days

TOTAL DAYS 11

Example:

Certifier has:

• 1 country where certified operations are located

• 75 operations 
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Audit Planning Guide- Example

Standard Duration (days) Total

Pre-Onsite 2 2

Onsite 2 2

Witness audit and/or 

review audits

1 1

Time Increase Factors

Number of countries 

with certified 

operations

1 additional countries 0

+ 0 days + 1 day per country

Number of certified 

operations

< 100 100-1000 > 1000 0

+ 0 days + 1 day + 2 days

TOTAL DAYS 5

6. Onsite Audits 

The objective of the onsite audit is to verify that the certifier has sufficient expertise in organic 

production and handling, and has the ability to comply with the USDA organic regulations. The 

audit team assesses a combination of certification offices (defined as “any site or facility where 

certification activities are conducted, except for certification activities that occur at certified 

operations or applicants for certification, such as inspections and sampling” under § 205.2) and 

certification files, and conducts witness inspections or operational visits to make this 

determination.

6.1 Pre-onsite review

Planning and preparing for the onsite audit can improve the efficiency of the audit. Numerous 

items can be reviewed prior to the onsite audit, including: 

a. Quality Manual; 

b. Policy and Procedure Manual; 

c. Annual Reports; 

d. Previous audit report; and

e. Certification files (at least one file should be selected onsite). 

6.2 Onsite Audit Process

Onsite audits include activities described in § 205.508. The audit team consists of a lead auditor 

and may include additional auditors or technical experts as determined by the scope of the audit. 

Employees and technical experts who have provided consultancy services or were employed by 

the certifier within two years of the audit may not participate in the audit.

Onsite audits are conducted in accordance with clause 6 of “ISO/IEC 19011: 2011 Guidelines for 

auditing management systems,” clause 7 of “ISO/IEC 17011: 2004 Conformity assessment—
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General requirements for accreditation bodies accrediting conformity assessment bodies,” these 

accreditation policies and procedures, and other applicable documents.

6.3 Onsite Review

If the certifier operates certification offices in addition to its main office, then all of its offices are 

assessed to ensure that sufficient objective information is collected to verify that the certifier’s 

program quality manual system and NOP certification requirements are effectively implemented 

and requirements are met.

a. The audit team assesses the certifier at the location(s) where it performs certification

activities. Certification activities include, but are not limited to: 

i. Certification management; 

ii. Administration; 

iii. Application review; 

iv. Inspection planning; 

v. Inspections; 

vi. Sampling; 

vii. Inspection report review; 

viii. Material review; 

ix. Label review; 

x. Records retention; 

xi. Compliance review; 

xii. Investigating complaints and taking adverse actions; 

xiii. Certification decisions;

xiv. Issuing transaction certificates;

xv. Policy formulation;

xvi. Process and/or procedural development;

xvii. Contract review;

xviii.Review, approval, and decision-making on the results of inspections;

xix. Adverse action decisions;

xx. Material, ingredient, and input review, approval and decision-making; and

xxi. Label review, approval, and decision-making.

b. Pre-decisional Audits

i. The audit team visits all certification offices under the scope of the accreditation.

c. Mid-term and Renewal Audits

i. The audit team visits the certifier’s main office during each onsite audit.

ii. The audit team also selects other certification offices to visit based on the

certifier’s total number of certification offices.

iii. All of the certifier’s certification offices are assessed during the five-year 

accreditation cycle.

7. Witness and Review Audits
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Witness and review audits are typically part of a larger onsite audit of the certifier. These can 

also be conducted independently of onsite accreditation audits. Examples include inspections to 

support complaint investigations, corrective action verifications, or those directed by the AD

Director.

Witness and review audits are selected based on the number of certified operations per scope and 

the geographical areas of operation. For certifiers with certification offices in addition to the 

main office, a witness inspection or a review audit will ultimately be conducted at each office. 

For certifiers with broad geographic reach, audits will be conducted at representative sites across 

that area. If a certifier certifies grower groups, at least one grower group must be selected as a 

witness or review audit within the 5-year accreditation cycle.

7.1 Witness Audits

Witness audits assess the performance of the certifier and the inspector(s) in verifying an 

operation’s compliance with the regulations, and determine whether the operation’s Organic 

System Plan (OSP) accurately reflects its practices. Specifically, a witness inspection ascertains 

whether the inspector(s) conducted the activities required by § 205.403(d)-(f). 

a. A witness audit of an operation must be an actual inspection, not a demonstration. 

b. One operation may be selected to witness audit multiple scopes of accreditation.

c. A representative of the operation must be present at all times during the witness

inspection. 

d. In addition to practices and procedures, the audit team should assess whether the 

inspector reviewed the operation’s corrective actions for any previously cited 

noncompliances.

e. Except for brief introductions, the audit team should refrain from asking questions or 

making comments during a witness audit. Questions or comments from the operation 

are to be directed toward the inspector or certifier’s representative.

f. The audit team may choose to leave a witness audit before the inspection is complete

if sufficient information has been collected. 

 

7.2 Review Audits

Review audits assess a certifier’s ability to fully comply with and implement an NOP 

certification program, assess the certifier’s oversight of the operation, and determine whether the 

operation’s compliance with the regulations observed during the review audit matches the 

findings in the inspection report. 

a. A review audit is not a witness audit. Rather, it is a broadly scoped visit by the NOP 

audit team with the operator to assess the certifier’s certification and oversight of the 

operation. 

b. Auditors lead the review audit, conducting interviews with the operation’s

representatives and other relevant persons. 
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c. Auditors should conduct a brief introductory meeting describing the purpose of the 

review audit, and a brief exit meeting with the operator to thank them for their 

participation. Auditors are to conduct a separate exit interview with the certifier to 

discuss the auditors’ findings. 

d. Auditors may use the review audit to investigate issues identified during the preonsite review or the onsite audit.

e. The audit team may interview the operation’s personnel to ask about the certifier’s

oversight activities.

f. When possible, auditors should assess whether the operation has implemented 

corrective actions for noncompliances identified by the certifier, and how the certifier

oversees the corrective action process.

g. Auditors can follow up with the certifier to clarify review audit events.

h. The audit team must complete NOP 2005-6 Audit Checklist – Review Audit when 

conducting a review audit. 

8. Certification File Review

The audit team conducts full and partial certification file reviews. This process should be started

before the onsite audit. All of the following items will be reviewed for full file reviews; for 

partial reviews, the audit team will determine which item(s) to review based on findings 

identified during the audit: 

a. File documentation (e.g., signed contracts, updated OSPs, inspection reports, decision 

sheets, label approvals, copies of certificates of organic operations, and other 

correspondence) is complete and up to date; 

b. Reports include sufficient information needed to make a certification decision, and 

decisions made by the certifier are appropriate with the evaluation of the certified 

operations’ OSPs, as applicable, and inspection reports;

c. The certifier has monitored the implementation of all necessary corrective actions that it 

requested from each certified operation; and 

d. The certifier is operating in accordance with relevant audit criteria, such as using 

appropriate personnel in the certification process, label compliance, handling of adverse 

actions, etc.

8.1 Certification File Review Requirements

• Pre-decisional Audit Certification File Review

Certification files are selected for the purpose of verifying the applicant’s ability to 

comply with its quality manual procedures, as required by §§ 205.503 and 205.504 of the 

regulations.

• Initial or Renewal Audit Certification File Review

The audit team selects certification files for review based on:
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i. The scopes of certification conducted by the certifier. If the certifier certifies 

producer groups (“grower groups”) at least one complete producer group file 

should be reviewed during the pre-decisional review, initial, mid-term and 

renewal audits;

ii. The geographic area(s) where the certifier certifies operations;

iii. Files the AD Director requests for review; and 

iv. A number of files, based on the number of certified operations, as outlined in 

Table 3.

Table 3 – Initial or Renewal Audit Certification File Review

• Mid-Term Audit Certification File Review

The audit team selects certification files for review based on:

i. The scopes of certification conducted by the certifier;

ii. The geographic area(s) where the certifier certifies operations;

iii. Files the AD Director requests for review; and

iv. A number of files, based on the number of certified operations, as outlined in 

Table 4.

Table 4 – Mid-term Audit Certification File Review

Number of certified 

operations Number of files to be reviewed

100 or less Between 5 and 7, 5 of which must be full reviews

101 - 240 Between 8 and 10, 6 of which must be full reviews

241 -400 11 or 12, 6 of which must be full reviews

401 - 1000 Between 13 and 15, 6 of which must be full reviews

More than 1000 Between 16 and 20, 6 of which must be full reviews

9. Audit Reports

Within 30 days of completing the audit, the audit team must prepare and submit to the AD 

Director a detailed report of the audit using the audit report template. The report must provide 

information on General Agency Information, Personnel, Certification Process, Administrative 

Number of certified 

operations Number of files to be reviewed 

100 or less Between 7 and 10, 6 of which must be full reviews

101 - 240 11 or 12, 10 of which must be full reviews

241 - 400 Between 13 and 15, 10 of which must be full reviews

401 - 1000 Between 16 and 20, 10 of which must be full reviews 

More than 1000 Between 21 and 25, 10 of which must be full reviews 
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Procedures, Fee Structure, Witness Inspections, and Findings, including the status of the 

effectiveness and implementation of corrective actions for previously cited noncompliances.

9.1 Review and Approval of Audit Reports

The AD Director reviews and approves the audit report and ensures the certifier receives a copy. 

a. If the audit report identifies noncompliances, a Notice of Noncompliance is issued to the 

certifier requesting proposed corrective actions within 30 days of receiving the Notice.

b. If no noncompliances are identified, then reports associated with pre-decisional or 

renewal audits are forwarded to the Accreditation Committee. For Mid-term audits, a 

Notice of Continued Accreditation is issued to the certifier. 

10. Corrective Action Review

a. The certifier is responsible for submitting sufficient corrective actions within designated 

timeframes when requested by the AD. 

b. The AD reviews the certifier’s proposed corrective actions and determines whether the 

noncompliances were adequately addressed. A corrective action report is prepared and a 

copy is provided to the certifier. 

i. Corrective action reports associated with initial or mid-term audits result in 

appropriate notices being issued. 

ii. Corrective action reports associated with pre-decisional and renewal audits are sent to 

the Accreditation Committee.

c. It is necessary to periodically conduct an onsite compliance audit to verify the 

implementation and effectiveness of corrective actions.

d. The NOP Deputy Administrator is responsible for either granting or denying 

accreditation, and may propose adverse actions for any unresolved noncompliances. 

11. Accreditation Committee Review

The Accreditation Committee reviews new and renewal accreditation applications as well as 

other select decisions, including scope expansion and reduction, and proposed suspensions and 

revocations. The Accreditation Committee prepares recommendations to the NOP Deputy 

Administrator for final accreditation decisions.

12. Accreditation Decision

 

The NOP Deputy Administrator either grants or denies accreditation. Decisions are based on the 

Deputy Administrator’s review of the information submitted in accordance with § 205.506(a)(3), 

the audit report, the Accreditation Committee’s recommendation, and any other relevant 

supporting documentation. 

a. Initial accreditation is granted for a period of five years from the date accreditation is 

approved. 

b. An unexpired accreditation is renewed for a period of five years from the end date of the 

previous accreditation term.
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The AD notifies the certifier of the decision and issues the appropriate notice.

13. Publication of Accreditation Status

Upon initial accreditation or any change in a certifier’s accreditation status, the AD updates and 

makes publicly available the accreditation status on the NOP Web site at

http://www.ams.usda.gov/nop. This includes:

a. The name and address of the accredited certifier;

b. The date of granting accreditation; 

c. Scopes of accreditation;

d. The certificate of accreditation,

e. The most recent audit report; and,

f. Areas of operation (states and countries).

14. Submission of Information

Certifiers must submit changes to policies, procedures, and operating protocols to the AD, 

pursuant to § 205.510(a);

Certifiers must maintain current and accurate data in the Organic Integrity Database for each 

operation which they certify, pursuant to § 205.501(a)(15).

15. Changing the Scope of Accreditation

Certifiers may request to add or remove scopes of accreditation at any time by submitting a new 

application to the AD. 

15.1 Extending the Scope of Accreditation

Certifiers must submit a new application that covers the added scope. A quality manual review is 

conducted and a pre-decisional onsite audit must be conducted prior to extending the scope. The 

pre-decisional onsite audit may be conducted independently or in conjunction with a mid-term, 

renewal, or other audit, as deemed appropriate by the AD Director.

15.2 Reducing the Scope of Accreditation

a. The AD reviews the request and prepares a report for review by the NOP Deputy 

Administrator.

b. Once approved, the certifier’s certificate of accreditation, list of certified operations, and 

any other relevant information, is updated to reflect its reduction in scope.

16. Cessation of Certification Activities
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A certifier whose accreditation is surrendered, suspended or revoked must adhere to the 

requirements described in § 205.665. 

16.1 Suspending or Revoking Accreditation

When a certifier fails to comply with the regulatory requirements for accreditation, the NOP 

Deputy Administrator follows the noncompliance procedures described in § 205.665.

16.2 Proposed Suspension or Revocation (7 CFR 205.665(c)) 

When a rebuttal is unsuccessful or correction of a noncompliance is not completed within the 

prescribed time period, the NOP Deputy Administrator shall send a written notification of 

proposed suspension or revocation of accreditation to the certifier. The notification of proposed 

suspension or revocation shall state whether the certifier’s accreditation or specified areas of 

accreditation are to be suspended or revoked. When correction of a noncompliance is not 

possible, the notification of noncompliance and the proposed suspension or revocation may be 

combined in one notification. 

16.3 Contents of the Notification of Proposed Suspension or Revocation 

The proposed suspension or revocation of accreditation will state: 

a. The reasons for the proposed suspension or revocation; 

b. The proposed effective date of the suspension or revocation; 

c. The impact of a suspension or revocation on future eligibility for accreditation; and

d. The right to file an appeal pursuant to § 205.681. 

16.4 Willful Violations

If the NOP Deputy Administrator has reason to believe that a certifier has willfully violated the 

OFPA or USDA organic regulations, the NOP Deputy Administrator will send a written notice 

of suspension or revocation of accreditation to the certifier.

16.5 Suspension or Revocation 

When the certifier fails to file an appeal of the proposed suspension or revocation of 

accreditation, the NOP Deputy Administrator will send a written notice of suspension or 

revocation of accreditation to the certifier. 

16.6 Surrendering Accreditation

Certifiers who no longer wish to maintain their NOP accreditation must surrender their 

accreditation by submitting a written notification to the AD Director.

Certifiers who discontinue certification services without notifying the NOP and do not surrender 

their certificate of accreditation or provide the NOP with records of their certification activities 
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will be issued a Notice of Noncompliance and Proposed Revocation for failure to comply with § 

205.505. 

16.7 Cessation of Certification Activities – Certification Clients

A certifier whose accreditation is suspended, revoked or surrendered must cease all certification 

activities in each scope and area of accreditation for which its accreditation is suspended, 

revoked or surrendered. Additionally, it must transfer its clients to USDA and make available 

any records concerning its certification activities that were suspended, revoked or surrendered. 

The NOP will work closely with certifiers before the suspension, revocation, or surrender date to 

ensure that the certifier’s clients have either found new certifiers or are in the process of 

surrendering their certification. Certification clients that do not respond will be issued the proper 

notices of noncompliance, proposed suspension, and suspension.

17. Appeals

Persons, as described in §§ 205.680 and 205.681 of the regulations, may appeal an adverse 

action such as a denial of certification or Notice of Proposed Suspension or Revocation to the 

AMS Administrator. Appeals must be filed in writing within 30 days of receipt of the Notice, 

and in accordance with the requirements described in §§ 205.680 and 205.681. They must be 

addressed to:

USDA AMS NOP

c/o NOP Appeals Team

1400 Independence Avenue, SW 

Room 2642, Stop 0268 

Washington, DC 20250 

Appeals may also be submitted electronically to: NOPAppeals@usda.gov

18. Complaints

a. Complaints Regarding AD Accreditation Activities and Certifiers

Any person or organization may submit a formal complaint to the AD regarding the NOP’s 

accreditation activities or an accredited certifier. By definition, a complaint is any expression of 

dissatisfaction, other than the appeal of an accreditation decision. Complaints regarding 

violations of the OFPA or USDA organic regulations by certifiers should be submitted to the 

Compliance & Enforcement Division.

To be accepted by AD as a formal complaint, the complaint must:

a. Be in writing;

b. State that it is a complaint;

c. Be submitted in English; 
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d. Be specific and include appropriate objective evidence to substantiate any claim of 

dissatisfaction with the NOP’s accreditation activities and/or a certifier; and

e. Be submitted within 90 days of the date the facts giving rise to the complaint became 

known to the complainant. 

Complaints should be submitted by email to AIA.Inbox@usda.gov, or by mail to the address in 

Section 4.1 of this Instruction. 

Upon receipt of the complaint, AD will review the complaint to determine whether it meets the 

above criteria. If it does not, the complainant will be notified in writing, within 10 days of 

receipt, that the complaint has not been accepted along with the reasons why. If the complainant 

is informed that their complaint has not been accepted, the complainant may revise the complaint 

or provide additional information, and resubmit it.

Upon acceptance by AD as a formal complaint, AD will ensure that the complaint is addressed in 

a timely manner. The NOP will notify the complainant once the complaint has been resolved. 

The written notification may include an explanation of how the complaint was addressed and the 

actions taken to resolve the issues.

19. Accreditation Fees 

Accreditation fees are assessed pursuant to §§ 205.640, 205.641, and 62.300, and 62.301, as 

appropriate. 

20. Contact Information 

For more information regarding NOP accreditation policies and procedures contact: 

Director, Accreditation Division

USDA, AMS, NOP

1400 Independence Avenue, SW 

Room 2648, Stop 0268 

Washington, DC 20250 

Email: AIAInbox@usda.gov 

21. References 

USDA Organic Regulations (7 CFR Part 205)

7 CFR 205.2 Terms Defined 

Certification activity. Any business conducted by a certifying agent, or by a person acting 

on behalf of a certifying agent, including but not limited to: certification management; 

administration; application review; inspection planning; inspections; sampling; inspection 

report review; material review; label review; records retention; compliance review; 
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investigating complaints and taking adverse actions; certification decisions; and issuing 

transaction certificates.

Certification office. Any site or facility where certification activities are conducted, 

except for certification activities that occur at certified operations or applicants for 

certification, such as inspections and sampling.

Person. An individual, partnership, corporation, association, cooperative, or other entity. 

7 CFR 205.403 On-site inspections. 

7 CFR 205.503 Applicant information.

7 CFR 205.505 Statement of agreement.

7 CFR 205.508 Site evaluations. 

7 CFR 205.510 Annual report, recordkeeping, and renewal of accreditation. 

7 CFR 205.640 Fees and other charges for accreditation.

7 CFR 205.641 Payment of fees and other charges.

7 CFR 205.665 Noncompliance procedure for certifying agents.

7 CFR 205.680 General.

7 CFR 205.681 Appeals. 

NOSB Recommendations

November 2008 Meeting, Final NOSB Recommendation on Certifying Operations with Multiple 

Production Units, Sites, and Facilities under the National Organic Program. 

Other Laws, Regulations and Standards

7 CFR 62.300 Fees and other costs for service.

7 CFR 62.301 Payment of fees and other charges.

International Organization for Standardization (ISO)/International Electrotechnical Commission 

(IEC) 17011 – Conformity Audit – General requirements for accreditation bodies accrediting 

conformity assessment bodies: 2004

ISO 19011:2002, Guidelines for quality and/or environmental management systems auditing

NOP Program Handbook: Guidance and Instructions for Accredited Certifying Agents 

and Certified Operations

NOP 2005 NOP Accreditation Assessment Checklist

NOP 2005-4 Witness Inspection Checklist 

NOP 2005-6 Audit Checklist – Review Audit 

NOP 2012 Accreditation Committee Procedure

NOP 4001 Complaint Handling Procedures
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Other References:

Form TM-10CG - Application for Accreditation

Form LPS-109 - Application for Service
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Attachment A

Instructions for Completing

TM-10CG Application for Accreditation

Form TM-10CG must be included in the accreditation application package for both initial and 

renewal applications. While the TM-10CG does not need to be submitted with annual updates, 

certifiers must notify the AD in writing any time information submitted on this form changes due 

to business relocations, personnel changes, or other events.

Except where noted, all applications must include the following basic business information:

a. Under “Business Name, Mailing Address, and Primary Office Location,” print or type the 

name of the accreditation applicant, and the applicant’s primary office location and 

address (include both mailing and physical addresses, if different).

b. Under “Name of person responsible for day-to-day operations” and “Title of person 

responsible for day-to-day operations,” enter the name and title of the primary contact 

person responsible for the applicant’s day-to-day operations.

c. Under “Tax ID,” enter the applicant’s tax identification number.

d. Under “Telephone Number” and “Fax Number,” enter the telephone and facsimile 

numbers of the primary office location or of the primary contact person.

e. Under “E-Mail address,” enter the applicant or primary contact person’s email address.

f. Enter the estimated number of operations the applicant plans to certify annually for each 

area of operation (crops, livestock, wild crop, and handling).

g. Check the type of entity applying for accreditation (e.g., Government, For-profit 

Business, Not For Profit Business, or Other).

h. After reading the affirmation statements, print or type the name and title of the person 

signing the form, and sign and date the form.
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Attachment B

Instructions for Completing

LPS-109 Application for Service

Form LPS-109 must be included in the accreditation application package for both initial and 

renewal applications. It provides the USDA Livestock, Poultry and Seed Program, which 

conducts documentation adequacy reviews as directed by NOP, with the authority to charge for 

its services. While the LPS-109 form does not need to be submitted with annual updates, 

certifiers must notify the AD in writing any time the billing address or the responsible party for 

the certification body changes.

To complete Form LPS-109:

a. Under “Name of Applicant” and “Billing Address,” enter the name and address of the 

person to whom accreditation billing information should be sent. This may be a street 

address or a post office box number.

b. Under “Physical Address of Service Location,” print or type the street address where the 

certifier’s office is located. Onsite audits will be conducted at this location. Do not use a 

post office box number. If the certifier maintains more than one office, this information 

should be included in another part of the application package.

c. Under “Tax ID Number” print or type the applicant’s tax identification number.

d. Under “Telephone Number,” print or type the phone number of the applicant or 

representative who signs the form.

e. Under “Email Address,” print or type the email address of the applicant or representative 

who signs the form.

f. Under “Grading Services,” “Type of Service Required,” check the box next to “Other” 

and print or type “Organic Accreditation.” Under “Verification Services,” “Type of 

Service Required,” check the box next to “Other” and print or type “Certifying Agent.”

g. Leave the box labeled “Legal Status” blank. This information is collected elsewhere.

h. Leave the box labeled “Financial Interest in Product” blank. This information is not 

applicable to NOP accreditation.

i. Print the form, and under “Signature of Applicant or Representative,” sign the completed 

form. Enter the date under “Date.”

j. Under “Print or Type Name of Signee,” print or type the name of the person who signed 

the form.