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The United States Department of Agriculture (USDA) National Organic Program (NOP)

USDA LogoThe National Organic Program (NOP) is a stand-alone certification program developed by the United States Department of Agriculture (USDA). It came into effect in October 2002 to regulate organic production, processing and marketing in the US. Under the NOP regulations, all members of the supply chain must be certified to the NOP standard.

This means that all suppliers and handlers of ingredients and/or products that are labelled, sold, or represented as ‘100 percent Organic’, ‘Organic’, or ‘made with Organic ingredients’ in the USA have to be certified under the NOP certification system. This includes farming inputs such as livestock feed and supplements, fertilisers and pesticides.

The NOP standard has a substantial scope covering fresh and processed agricultural food products including crops and livestock, however currently there is no standard for the processing of fibre. This does not preclude the labelling of fibre as NOP organic as long as the production is certified NOP and the processing aids used to manufacture the fibre comply with the USDA NOP standard and its national list.

Certification bodies need to be accredited by the USDA in order to offer this certification program. In Australia, there are three certification bodies who hold this accreditation: NASAA, ACO and OFC.

There are a number of key differences in the certification and inspection process between the Australian process and USDA NOP. To start with there is no conversion period, as at least three years compliance needs be demonstrated at point of application. In addition, the system is not retrospective as it is forward looking and certification will be only granted following point of application, initial positive inspection and review.

Like the Australian domestic certification, the cornerstone of the certification for NOP is the Organic Management plan (OMP), which is referred to in the NOP system as the Organic System Plan (OSP). When application for NOP is submitted to a certification body, an OSP is completed detailing the operations management plans for the upcoming season.

The certification body reviews this information, and will confirm that the plans are substantially compliant with the NOP standards before an initial inspection is scheduled. The OSP is the forum wherein the producer or handler and certifying agent collaborate to define how to achieve and document compliance with the requirements of certification.

It is the producer/handlers statutory declaration of what they will do in the next 12 months to be compliant with the NOP standards. Moreover, it commits the producer/handler to a sequence of practices and procedures resulting in an operation that complies with every applicable provision in the regulations.

Finally, it must be reviewed, negotiated and approved by the certification body prior to the inspection being carried out. The inspector will then verify, mainly through documentation and physical evidence that the OSP has been followed.

USDA NOP – National list

Another major difference is that the NOP standards provide a list “The National list” which contains criteria for determining which substances and ingredients are allowed or prohibited in products to be sold, labelled, or represented as organic or made with organic. Basically, all non-synthetic substances may be used provided they are not specifically prohibited on the national list and they are not produced using GMO's, irradiation, and/or sewage sludge.

The National list goes a step further to itemise those synthetic substances that are also allowed.

Implications for Australian livestock producers

One of the major issues for Australian certified producers who are considering undertaking NOP certification is that all livestock feed needs to be certified 100% organic and in addition the feed inputs such as molasses, apple cider vinegar and garlic, need to be also NOP certified.

Extinosad is a popular product in organic management systems used to control insect species, including the sheep body louse (Bovicola ovis) and the sheep blowfly (Lucilia cuprina) and its larvae. It contains the active ingredient, spinosad, which is derived from the naturally-occurring soil bacterium, Saccharopolyspora spinosa.

However, this product contains a number if inactive ingredients that are not on the National List and therefore this product cannot be used in NOP certified livestock operations.

If you are thinking about marketing organic products internationally, then the US does represent a considerable market. To help you understand how you can gain access to that market, this section has covered:

* The National Organic Program

* US certification bodies

* The certification process for the US market, and

* The National list
 
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