TOS 212. October 2026. Article 5

In the United States, organic is a process-based standard. Accredited certification agencies (also referred to as certifiers) are tasked with verifying compliance with the regulations through inspection, document and process review, and various checks such as mass balance audits, supply chain traceability audits, and residue testing. Certifiers and their staff have always been tasked with exercising critical thinking to make site-specific risk assessments. A certifier is not tasked with turning over every stone – but rather has the more complex job of assessing where each operation’s unique risk factors are (when it comes to compliance and fraud), identifying critical control points for verifying compliance. and developing an approach to verifying compliance that is appropriate for the specific operation.

Over the more than twenty years since the USDA National Organic Program (NOP) regulations were finalized, certifiers have developed systems and approaches to this risk-based certification.

But an opportunity to dig in a bit more arose following implementation of the Strengthening Organic Enforcement (SOE) Final Rule in Spring 2024. That rule, which is part of the USDA organic regulation, is the largest organic regulation since the NOP’s beginnings, was intended to reduce fraud in the organic marketplace; strengthen oversight of organic producers, handlers, and certifiers; and improve USDA’s enforcement mechanisms. The rule created stronger tools and processes that help ensure compliance; implemented robust and consistent enforcement of the organic regulations; improved farm to market traceability; enhanced consumer and farmer trust in the USDA organic label; and created a level playing field for organic farms and businesses.

Perhaps unintentionally – or at least tangentially – it did more than that. It increased certifiers’ kit of tools to verify compliance, naming tools such as supply chain traceability audits, organic fraud prevention plans, import certificates, and more. And it placed a bit of pressure on certifiers to do more.

But the intention of that rule was not for certifiers to do more to verify compliance for all operations – but to do more to root out fraud and noncompliance. Applying all of these new tools bluntly across all operations was never the intention of the rule. The intention of the rule was to empower certifiers and their staff to use critical thinking and apply a risk-based perspective to determine what tools are most needed in higher-risk situations; and what tools are most needed in lower-risk situations – all in service of verifying compliance, maintaining integrity, and rooting out fraud.

Certifiers were faced with an opportunity. How do we use these new tools to root our fraud and verify compliance – while continuing to apply a risk-based lens to our work? How can we ensure our limited resources are available to focus on areas of highest risk for fraud or lack of compliance; while continuing to ensure all operations’ compliance is verified. The organic regulations talk a little bit about additional tools to use for a high-risk operation; but how can we streamline certification for lower-risk operations?

Over the past two years, certifiers, with the support of the Accredited Certifiers Association, have been leaning in to a stream of collaborative work focused on identifying opportunities to use a risk-based lens to streamline certification, ensuring all operations’ compliance is verified, but the right tools and resources are used to verify based on a site-specific risk assessment. What has this looked like?

• Developing risk assessment tools that help certifiers know where to devote more resources, and where a simple check may be sufficient.
• Developing best practices for when a virtual audit may be sufficient to verify compliance.
• Developing common forms – such as the Common OSP – that allow certifiers to pull resources back from form development and shift them to verification.
• Finding areas to streamline certification processes – such as the application process or the annual review process – to create efficiencies that allow certification staff to focus their efforts where they have the most impact.
• Investing in training – online and in-person, and available to inspectors, certification review staff, and management – to create muscle memory and confidence around risk-based certification.

Certifiers can choose if and how to incorporate the suggestions from the best practices into their processes. (The Common OSP is published on the NOP’s website, but it is not mandatory for certifiers to use it)

To be clear, none of this is intended to reduce enforcement rigor. Certifiers continue to verify compliance with the regulations for all operations. But this is right-sizing the approach, as the regulations suggest through their references to site-specific compliance.

Not only does this collaborative work ensure that certification resources are focused on digging deeper where there is greater impact to organic integrity, but it also has positive impacts on certification staff and organic operations. For certification staff, finding these efficiencies and streamlining processes reduces duplicative work, and with time should right-size workloads. And for operations, a reasonable site-specific approach to verification should streamline lower-risk inspections, make them more sensible, and create more trust and understanding of the certification process.

While it will take time, and leaning in to critical thinking and streamlining can be nerve-wracking, we believe this shift to a more collaborative, more streamlined, more risk-based approach will lead to stronger integrity of organic overall, improved morale for organic inspectors and certification professionals, and heightened satisfaction with the certification system for organic farmers and other operations.