United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 11-2

Agricultural Marketing Service Room 2646-South Building

National Organic Program Washington, DC 20250

NOP PM 11-2 Certification of agricultural products that meet NOP Standards Rev02 10 31 11 Authorized Distribution: Public 

Page 1 of 1

Policy Memorandum

To: Stakeholders and Interested Parties 

From: Miles McEvoy, Deputy Administrator 

Subject: Retained Memo: “Certification of agricultural products that meet NOP standards” 

Date: Original Issue Date – January 31, 2011

Attached is the “Certification of agricultural products that meet NOP standards” memo issued by 

former Transportation and Marketing Programs Deputy Administrator Barbara C. Robinson on 

August 23, 2005. This memo is being retained by the NOP as a new policy memo and remains in 

effect. This document has been assigned the control number “PM 11-2”.

Enclosure: “Certification of agricultural products that meet NOP standards” August 23, 2005 

memo
August 23, 2005 

MEMORANDUM

TO: All USDA Accredited Certifying Agents

FROM: Barbara C. Robinson 

Deputy Administrator 

Transportation and Marketing Programs 

Agricultural Marketing Service

SUBJECT: Certification of agricultural products that meet NOP standards 

The National Organic Program (NOP) has received numerous inquiries regarding its 

current thinking on the issue of products that meet the NOP program standards for organic 

products based on content, irrespective of the end use of the product. This statement is intended 

to clarify the NOP=s position with respect to this issue, and will be provided to all of our 

accredited certifying agents.

Agricultural commodities or products that meet the NOP standards for certification under 

the Organic Foods Production Act of 1990, 7 U.S.C. §§ 6501-6522, can be certified under the 

NOP and be labeled as “organic” or “made with organic” pursuant to the NOP regulations, 7 

C.F.R. part 205.300 et seq. To qualify for certification, the producer or handler must comply with 

all applicable NOP production, handling, and labeling regulations. 

Operations currently certified under the NOP that produce agricultural products that meet 

the NOP standards to be labeled as “organic” and to carry the USDA organic seal, or which meet 

NOP standards to be labeled as “made with organic”, may continue to be so labeled as long as 

they continue to meet the NOP standards. Such certification may only be suspended or revoked 

after notice and opportunity for hearing. 

There are agricultural products, including personal care products, that, by virtue of their 

organic agricultural product content, may meet the NOP standards and be labeled as “100 percent 

organic”, “organic” or “made with organic” pursuant to the NOP regulations. Businesses that 

manufacture and distribute such products may be certified under the NOP, and such products may 

be labeled as “100 percent organic”, “organic” or “made with organic” so long as they meet NOP 

requirements. Additionally, products that may be labeled “100 percent organic” or “organic” 

may also carry the USDA organic seal. If additional rulemaking is required for such products to 

address additional labeling issues or the use of synthetics in such products, the NOP will pursue 

such rulemaking as expeditiously as possible.