FAQ

Periodically, the Canadian Organic Trade Association (COTA) offers grants for organic farming.  To learn more about this organization and potential funding opportunities check out their website or contact them at 613-482-1717.

The certification of organic products by an accredited Certification Body assures consumers that products have been produced or processed to national or provincial standards for organic production.

Aside from the quality assurance that certification provides, provincial organic certification regulations regarding the labelling and marketing of organic products in B.C. changed in 2018. All producers, processors and handlers of organic food and beverages require documentation to prove that their products (and/or processes) are certified by an accredited Certification Body.

PROCESSORS:

If you wish to add products to your organic certificate please send an email to PACS along with :

• Organic documentation for ingredients
• OPP (product recipe form)
• Label
• Additional information including sales jurisdiction, expected launch date, process/process flow information (if different from existing stock)

Growers

• Crops must be inspected to be added to a certificate. If you have changed your cropping plans after your renewal submission, please contact the PACS certification committee with the details.
• If adding land, please contact the PACS Certification Committee prior to your inspection.

Contact the certification committee as soon as possible to ensure we can incorporate any additional production units to your annual inspection. You will be required to submit the land use history so we can review input usage in the previous 36 months, along with a landowner declaration and updated map. Upon a successful inspection, and verification that the land has been free of prohibited substances for 36 months, the production units will be added to the scope of your certification.

Operations that provide a service to their organic clients such as slaughterhouses, transportation companies, storage facilities, and seed cleaning plants may wish to obtain an Attestation of Compliance (AoC), which is a certification whereby they can offer their certified organic services to an organic clientele base.  If a service provider does not wish to apply for certification, they will be required to fill out a Third-Party Service Provider declaration (available on the PACS website) and, in some cases, will require an inspection.  It is important to contact PACS prior to the use of any third-party service so the Certification Committee can ensure the required documentation is completed, and an inspection is scheduled (if required) prior to completion of the service.

This program is ideal for agricultural producers and processors who are located outside of B.C., and who sell within their own province, or territory, only.  Products may be marketed as “certified organic” and may use the PACS logo on labels and in marketing material but may not cross provincial/territorial borders with an organic claim. With this PACS certification, processors are permitted to use ingredients in their multi-ingredient products that are not only PACS-certified, but also those certified to the BCCOP and COR programs, and any program deemed equivalent to COR by the CFIA (see Organic equivalency arrangements with other countries).  The PACS logo may also be customized with the operator’s PACS number.

Land-based activities are subject to a mandatory period of transition from an initial application to organic certification.  Transitions periods will be a minimum of 12 months and up to 36 months, depending on the last date of application of a prohibited substance.

Canada currently has equivalency arrangements with Costa Rica, European Union, Japan, Switzerland, Taiwan, the United Kingdom, and the United States. Many COR-certified products qualify for organic equivalency in these countries.  To learn more about qualifying products, please contact the PACS Certification Committee or review the information on the CFIA website, Organic equivalency arrangements with other countries. 

Products classified as food commodities, seed, or feed are eligible for certification to COR. PACS certifies scopes of production such as crop, livestock, greenhouse, multi-ingredient food/feed preparation, as well as the handling activities of traders/distributors, and contracted packaging & labelling activities of organic products.

Yes, an operation may be certified to both COR and BCCOP.  If, for example, an operation requires COR certification for selling organic products outside of B.C., but also wishes to use the B.C. Checkmark symbol on labels and in marketing material, that operation may also apply for both COR and BCCOP certification.  There is no additional charge for being certified to both programs. Simply indicate on your application for certification (or annual for renewal) that you are applying for certification to both programs.

Unfortunately, the CFIA does not recognize BCCOP certification as being equivalent to COR, so a BCCOP-certified ingredient is not considered to be an organic ingredient when used by a COR certified operation.

Products certified to BCCOP are considered certified organic only within British Columbia. These products will not be considered “certified organic” ingredients by COR certified operations.

Many organic enterprises with exemplary recordkeeping and straightforward operations (small crop operations as opposed to multi-ingredient processors, for example) have a low risk of non-compliance whereby they do not export organic products out of their own province or territory and have not had non-compliances in their last three inspections. These enterprises may be evaluated for participation in the Low Risk Program after receiving an organic certificate in all of the previous three years. Participation in the Low Risk Program requires that annual renewals are submitted on time; however, the requirement for inspection is extended to at least once every three years which results in significant cost savings.  For details on the specific criteria for risk assessment and eligibility to the Low Risk Program, please contact the PACS Certification Committee. 

PACS is accredited by the COABC (Certified Organic Associations of British Columbia) and, therefore, provides BCCOP certification to operators who are in B.C. and wish to have BCCOP certification as opposed to COR.  Products certified to BCCOP may not be sold outside of B.C. with an organic claim, nor can they be used as ingredients in COR certified products. BCCOP certification covers some products not eligible for certification under COR such as cut flowers, Christmas trees and fallow land that is not yet in production. Operators who are currently certified under the COR program may wish to add products that are only certifiable to BCCOP, which is permitted. In this case, PACS will take care of this distinction for you on your organic certificate. 

The risk assessment program is defined within the BC Certified Organic Program.

The program allows small-scale low-risk producers to reduce their costs by allowing inspections only once every three years.

The risk assessment criteria are not recognized under the Canada Organic Regime (COR); therefore, operations that intend to sell products outside of their home province or territory do not qualify for the program.

Eligible operations in BC will be certified to the BCCOP. Eligible operations out-of-province will be certified to PACS only.

Following a VO risk assessment, the PACS Certification Committee will review and determine if an operation qualifies for entry to the Low Risk Program.

Crops grown in buffer zones are NOT considered organic; therefore, if buffer zones are harvested, the harvesting/storage equipment must be cleaned and/or separate from that used for organic crop harvesting and storage.

For new installations or replacement purposes, fence posts or wood treated with prohibited substances are prohibited.  Recycling of existing fence posts treated with prohibited substances within the operation is permitted. For a new applicant to organic production, a 36-month transition period applies to production units where treated posts were installed (36 months from the date of installation).  If an existing organic operation installs treated posts, this will lead to decertification of the production units where the posts were installed.

All land-based activities (crop and livestock) must undergo a transition period. The Canadian Organic Standards must be applied to a production unit for at least 12 months before the first harvest of organic products, and proof must be provided that prohibited substances have not been used on the land for at least 36 months. After the receipt of all forms and payment of initial application fees, the operation is considered under the supervision of PACS and the 12-month transition period begins upon that date; during which time an initial inspection and certification review will take place. Following a second successful inspection, and after the 12-month transition period, crops qualify for organic certification status.

You must search for organic seed from 3 or more potential sources and retain documentation of your search, which will be verified at your inspection. Any non-organic seed you source must be proven (declaration from the supplier) to be untreated, or treated with permitted substances only, and non-genetically engineered (non-GE). “Seed or Planting Stock” declarations are available on the PACS website which may be sent to seed suppliers to confirm that their seed, or planting stock, is compliant with the organic standards.

A buffer zone is a clearly defined, identifiable boundary, that separates an organic production unit from adjacent non-organic areas. If unintended contact with prohibited substances is possible, a distinct buffer zone (at least 8 m wide), or a feature that prevents contamination, such as a hedgerow, windbreak, or other physical barrier, is required.

Fence posts can be treated with substances listed on the Permitted Substances List (PSL), Table 4.3.

If there are existing fence posts in use within an operation that are treated with a prohibited substance such as CCA (for example), or if a new operation is purchased that already has fence posts in place, those posts can remain in use and/or be recycled within the operation.

If a new applicant installs treated fence posts while in their transition period, this would result in a 36-month transition of the specific production unit where they were installed.

If an existing certified organic operation installs treated posts, decertification could result if they cannot prove due diligence for the commercial availability of an alternate choice.

Animals purchased for breeding should be organic; however, if suitable organic livestock is not available, and non-organic breeding stock are purchased in order to expand the existing organic herd, the animals must be non-gestating when brought onto the organic operation. They must be managed organically and will be considered “organic” for breeding purposes only (i.e. calves born to non-organic breeding animals can be certified organic).  A non-organic animal can never transition to organic status for organic meat production.

All land-based activities (crop and livestock) must undergo a transition period. The Canadian Organic Standards must be applied to a production unit for at least 12 months before the first harvest of organic products, and proof must be provided that prohibited substances have not been used on the land for at least 36 months. After the receipt of all forms and payment of initial application fees, the operation is considered under the supervision of PACS and the 12-month transition period begins upon that date; during which time an initial inspection and certification review will take place. Following a second successful inspection, and after the 12-month transition period, crops qualify for organic certification status.

• As long as the land has been verified to be free of prohibited substances in the last 36 months, the land will be added to your scope of certification following your annual inspection. If prohibited substances have been used, the land must transition to organic 36 months following the last date of the application of a prohibited substance.
• If the land qualifies for 3rd year transitional, bred females may be brought onto the operation and my graze transitional pasture until the end of their 2nd trimester.  These newly added females must then be under continuous organic management (fed organic feed and graze on organic land only) from the beginning of their last trimester for the calves to be considered organic.
• Non-organic breeding stock bought onto the organic operation are considered “organic” for breeding purposes only. The meat from these animals can never be sold as organic.
• Livestock existing on-farm when new land in transition is added to the operation may not graze transitional pasture and maintain organic status.

Non-organic dairy cattle may be brought onto an organic operation as long as they are neither in gestation nor lactating. Once on-farm, they must be managed organically for at least 12 months before their milk can be considered organic.  NOTE: it is important to keep accurate records so a Verification Officer can verify that milk from animals in transition is not being sold as organic.

No. Offspring of meat animals will be considered certified organic only if they were born after the land transition is complete.

In order to use an organic ingredient in your product that is certified outside of Canada, it must meet an equivalency arrangement with the Canada Organic Regime (COR). Products grown in countries outside of Canada that are certified through the United States’ National Organic Program (NOP) will be recognized as being equivalent in Canada, provided they are accompanied by a current organic certification document, as well as a US/Canada Organic Equivalency Arrangement (USCOEA) statement. Products grown in the 28-member states of the EU that are accompanied by a current organic certificate will be recognized as equivalent in Canada under the EUCOEA.

In order for a USDA NOP-certified product to be equivalent to COR standards, it needs to be accompanied by an attestation that declares equivalency. The attestation confirms the following:

1. The product was not produced using sodium nitrate (Chilean nitrate).
2. The product was not grown using hydroponic or aeroponic production methods.
3. Agricultural products derived from animals (with the exception of ruminants) were raised according to livestock stocking rates set out in Canada’s Organic Standards (CAN/CGSB 32.310 - 2015).

Current organic certificates are required for all Organic Ingredients used in your products. Any new suppliers must be approved by the PACS Certification Committee prior to use as an ingredient by submitting organic certification documents, and corresponding equivalency documentation (if applicable) for review.

PACS requires a copy of your suppliers’ organic certificates on-file, and you must also keep records on-site as the Verification Officer will inspect these documents during your inspection to ensure they are current and correspond to the date(s) of ingredient shipments.

If there are any Non-organic ingredients used in your product, a Non-Organic Ingredient (NOI) form is required to ensure the product complies with COR standards.

An Organic Product Profile (OPP), is essentially a recipe/list of ingredients, both organic, and non-organic that PACS keeps on-file for every processed multi-ingredient product that an operation certifies as organic. The OPP worksheet calculates the percentage of organic ingredients and lists all product suppliers and their certification bodies.

Every time you have an ingredient and/or supplier change, or wish to add a new product for certification, a new OPP must be filled out, and submitted to the PACS Certification Committee for review and approval.

Upon approval of your OPP and corresponding label, a product may then be added to your organic certificate.

A Manufacturer Declaration is used to obtain:

• the quantity of water and/or salt, which is excluded from the organic percentage calculation of your final product IF you list water and/or salt on the final product label
• the total organic percentage of a multi-ingredient ingredient, which is used in the OPP to calculate the total organic percentage of your processed product.  NOTE: if a manufacturer does not disclose the organic percentage, the default values of 95% and 70% will be used for Category 1 (>95%) and Category 2 (70-94.9%) products, respectively.

In order to maintain organic integrity, organic products must be separated from non-organic products during all stages of production and storage.

If an organic processing run follows a non-organic processing run, a removal event must occur. Depending on the nature of the products and the processing facility, a removal event may involve the cleaning of equipment with approved products or purging the processing equipment with a run of organic ingredients (following which they may not be used in certified organic products).

Documentation must be available for the Verification Officers to audit organic vs. non-organic ingredient volumes and product sales.

In order for a finished product to bear an organic label, the entire product (all ingredients, additives and processing aids), and the processes used to produce the product, must be verified to follow the Canadian Organic Standards, and subsequently certified by an accredited Certification Body.

Since the processing of wine takes place over several months, winemaking is somewhat unique in the world of Preparation. PACS can certify the winemaking process prior to the bottling of organic wine; however, the initial inspection of the operation must take place within a reasonable timeframe of the first organic crush of the season. If you already have a certified organic vineyard, a great place to start is with the following document: Adding your Winery/Cidery to the Scope of your Certification. Contact the PACS Certification Committee for more information and we will be happy to help you with certifying your winery!

Crops grown in containers, whether indoors or outdoors, must be grown in planting media that contains at least 2% by dry weight or volume of minerals (sand, silt, or clay, excluding perlite and vermiculite) at the start of the production cycle.  There must also be a biological fraction which contributes to soil structure; and except for seedling/starter mixes, the media must be composed of at least 10% compost by volume. Pre-mixed planting media may be used but keep in mind that all products must first be approved by the Certification Committee.  Planting media must contain no prohibited substances.

For COR-certified operations, we can confirm that products listed on the certificate are in compliance with the US-Canadian Organic Equivalency Agreement and under that equivalency arrangement, the USDA logo could be used. There are some major exceptions, such as dairy products (for instance).

Labelling information can be found in the:

PACS Handbook for Organic Operators. Please contact PACS to request this booklet.

And the Canadian Food Inspection Agency (CFIA) website.

NOTE: All labels must be approved by the PACS Certification Committee prior to use in the marketplace.

If your enterprise is in B.C., and is certified to the BCCO program, you may use the B.C. Checkmark symbol, and/or the PACS logo.

If your enterprise is COR certified, no matter where your enterprise is located, you may use the COR logo, and/or the PACS logo. NOTE: COR-certified products may not use the term “Certified Organic” anywhere on a product label other than within the “certification statement”.

If your enterprise is in B.C. and you require, or wish to have, COR certification, and you wish to use the B.C. Checkmark symbol, you may certify qualifying products to both the COR and BCCO programs.  The COR logo, and/or the B.C. Checkmark symbol, and/or the PACS logo may be used in this instance.

The "100% organic (product name)" claim is not permitted in Canada.

All products with an organic content of 95% or greater are considered organic and may be labelled with the word "organic".

The claims "made with organic ingredients" or "made with organic (grapes, for example)" are not acceptable as it is not clear how much of the product is made with organic ingredients.

Products with 70-95% organic content must declare the percentage of organic content on their label.

Products with less than 70% organic content may only indicate which ingredients are organic in the ingredients list.

Producers who are federally licensed for the cultivation of cannabis, or who are in the process of applying for a federal licence, may apply for organic certification. To qualify for organic certification under the Canada Organic Regime (COR), a product must be an agricultural food product intended for human or animal consumption. Cannabis is not considered a food product and is not recognized by the CFIA as qualifying for COR certification; therefore, PACS has developed internal organic certification programs for the organic certification of legally produced cannabis. 

The PACS organic certification program for Indoor Cannabis Cultivation (indoor containerized production), is based on the Crops Grown in Structures or Containers section of the Canadian Organic Standards. Following an initial inspection and successful certification review, a PACS organic certificate will be issued to the operation, provided they are a federally licensed producer.  If the Health Canada (HC) licence has not been issued, receipt of an organic certificate will be withheld until the operation receives its HC licence.

The PACS organic certification program for Outdoor Cannabis Cultivation is based on the principal aspects of the Crop production section of the Canadian Organic Standards.  Outdoor, in-ground, production is considered a land-based activity and is subject to a minimum transition period of 12 months within which 2 inspections must be completed. The land must also be freed of prohibited substances for a minimum of 36 months prior to issuance of an organic certificate; therefore, if prohibited substances had been applied during that time, the transition period would increase accordingly. An operation in transition will receive a letter indicating their transitional status and their organic eligibility date.  Upon a successful inspection during the year of organic eligibility, pending their receipt of a federal licence for cannabis production, an operation will be issued a PACS organic certificate (note: the certificate will not be issued prior to the organic eligibility date). If the HC licence for cannabis cultivation has not been received by the date of organic eligibility, fallow land may be certified to BCCO program to maintain its organic status.

Because cannabis is not considered a food product and not certifiable to COR, its processed derivatives are also not eligible for certification to COR.  PACS will certify processed Cannabis products (oils), providing the operation holds a valid Health Canada licence for Cannabis Processing, to the in-house PACS Cannabis Processing certification program.  This program is based on the COR standards for food preparation.   Products may be marketed as organic but may only bear the PACS logo. They may not bear the COR, USDA or EU logos, or the organic logos of other countries with which Canada has equivalency arrangements.

You may apply for certification if you wish to start the organic certification process; however, if your Health Canada licence application is declined, we will not be able to proceed with organic certification of your cannabis operation. If you are an outdoor operation and wish to apply for certification of the land only, so that it transitions and is ready for cannabis production at a later date, you may do so.

We understand that Health Canada has strict requirements regarding what can and cannot be included on a cannabis product label.  We ask that if you are only able to add one organic ‘element’ that it be the certification statement “Certified Organic by PACS”. Please note that all labels must be submitted to PACS for approval of the organic elements.

When certified to a PACS internal certification program, an operation is eligible to use the PACS logo only (not the BCCOP or COR logos).  If you are able to incorporate the PACS logo on your cannabis labels, or in your marketing material, you may certainly do so. Please contact our Admin team for more information on the logo graphics and approved colour schemes.

Products that display medicinal claims, dosages, or an NPN (Natural Product Number) fall outside the scope of COR certification; therefore, PACS has developed an internal certification program for such products based on the COR standards.  Organic ingredients must be agricultural products, certified to COR or equivalent standards, and non-organic ingredients must comply with Health Canada criteria and that of CAN/CGSB-32.310 clauses 1.4 and 1.5.

Natural Health products certified to the PACS internal certification program may bear the PACS logo only and may bear neither the COR logo nor BC Checkmark symbol. Since the products are not certified to COR, that means they do not qualify for organic equivalency arrangements with other countries and may not bear their organic logos.

PACS does not currently certify cosmetic products; however, this certification program may be offered in the future.

Every enterprise will have an on-site inspection conducted annually of each production unit, facility and site that produces or handles organic products. All scheduled inspections must be conducted at a time when an authorized representative of the enterprise, and who is knowledgeable about the operation, is present. Operators must arrange for the Verification Officer (VO) to have access to all areas and operation records.

PACS may conduct additional inspections of both new applicants and certified operations to determine compliance with the standards. Additional inspections may be announced, or unannounced at the discretion of PACS. Note: 5% of operators are subject to unannounced inspections annually.

The initial certification of a crop-based enterprise requires two inspections prior to obtaining approval for certification: an initial inspection and a second inspection within the following year.

Depending on the timing of your inspection, if your harvest has not yet taken place, please have the previous year’s records available for the VO to audit.

Crop

• Crop rotation & soil Improvement plans
• Disease and pest management plans
• Input record – dates, rates, locations, invoices
• Harvest and Sales records (mandatory for completion of audits)

Livestock

• Inventory of all animals onsite
• Records to verify purchases/dispersals
• Inventory of all health care products onsite.
• Verifying size and stocking rate for all pens and pastures (indoor and outdoor).
• Audit of health care records for the year.
• If animal products are sold ( meat, eggs) ensure inventory records and sales invoices are available

Preparation

• Every effort will be made to ensure there is an organic production run in progress during the inspection.
• Product list, plant diagram, flow cart, OPPs will all be reviewed and verified at every inspection.
• Supplier certificates corresponding to most recent purchases must be onsite
• Sanitation SOPs and all cleaners onsite will be verified
• Traceability code/mechanism will be verified
• Production, inventory, and sales records (mandatory for completion of organic audits)

PACS requires notification of the sale of the operation and an application form submitted from the new owners which will identify any pertinent information with regard to changes within the operation. The operation will also require an inspection under the new ownership; the annual inspection may be timed so that it takes place following the purchase of an operation, but this will need to be coordinated with PACS.

NOTE: The Low Risk status cannot be transferred to a new owner. A new purchaser must apply for certification, which requires an annual inspection.

Questions about the meaning of a particular point in the Canadian Organic Standard may originate from any source and are directed to the Canadian Organic Office at opr.rpb(@)inspection.gc.ca There is no specific comment form on which stakeholders should present their questions. If the operator belongs to a certification body (e.g. PACS) they should first, ask them. click here to learn more

PACS clients are always welcome to contact the Certification Committee to inquire about the interpretation of the organic standards. If we are unable to answer a question, we will send an inquiry to the COABC (Certified Organic Associations of BC) and/or the SIC (Standards Interpretation Committee).

On the 19th of March 2024, after which all organic products exported to the USA will require an accompanying NOP Import Certificate (NOPIC). 

Import Certificates (NOPICs) are a key part of SEO’s integrated strategy. It provides an auditable record trail of the import process and supports traceability and verification of organic integrity. The NOP will use NOPICs to reconcile information submitted to US Customs and Border Protection to verify the status of organic products imported into the USA, or flag products that do not conform.

If you export to the United States, where you are the owner of the organic product at the time of export (the final ‘handshake’ before a product is received by the US Importer), then you will be impacted by the USDA’s SOE and will be required to request NOPICs from PACS to accompany your export shipments.

Do you sell your organic product directly to a buyer (importer) in the United States? If so, then you are exporting. Even if you hire a contractor to arrange the export process/logistics, if that exporter doesn’t own the product when it crosses the line, then you are the exporter. 

The following activities do not make you an exporter: 

• Selling your crop to a packinghouse who then distributes products that the packinghouse now owns. 
• Selling your product to the end consumer in the USA (either directly, or through a third party like Etsy). This activity falls under the SOE’s retail exemption.
• Selling your product to a distributor in Canada, who may sell to the USA after the sale of your product.

If you sell your product to an entity in Canada, you are likely not an exporter (regardless of where the product ends up after that sales transaction is complete). 

You are still the exporter, unless you are selling your product to that company (at which point they would own the product and become the exporter).  

Yes. Regardless of whether your labels use the USDA organic seal, your labels must be assessed by PACS if they are destined for the USA. 

NOPICs (NOP Import Certificates) must display the product name ‘as labeled’. This means the product name on the NOPIC must be the same as the name displayed on the product packaging’s principal display panel. PACS must also ensure that all US-bound labels meet the criteria established in the Code of Federal Regulations. 

Bulk products must display a minimum amount of information to comply with traceability requirements. 

Before PACS adds a product to your Organic Integrity Database profile, PACS must verify that all labels are compliant. For details on the label requirements for the USA, visit: https://www.ams.usda.gov/rules-regulations/organic/labeling. 

The USDA’s SOE has expanded the requirements for organic certification across the supply chain. 

Essentially, any enterprise that handles organic products requires certification. 

There are few exemptions to the certification requirement; these are generally aimed at enterprises that handle products in their final, sealed, tamper-evident packaging (and remain in that same packaging). However, the exemptions are very limited and specific. For more information on SOE, including descriptions of enterprises that are exempt from the requirement to be certified organic, please visit the USDA's Primers on SOE.

If you are a Canadian handler of organic products and would like to proceed with obtaining certification, PACS will be happy to help you!

Yes! Please contact PACS with your intent to export, so we can ensure that you are included in all future communications and updates on SOE. 

Your enterprise will also be required to implement an Organic Fraud Prevention Plan along with robust record-keeping and control systems. If you do not already have these in place, now is a good time to begin. 

Please email admin@pacscertifiedorganic.ca with your NOPIC request. We will send you the NOPIC Request Form or you can download the most recent version here. 

NOTE: operators who intend to export to the USA should contact PACS immediately with their next anticipated export date. 

You must have your valid NOP Import Certificate prior to scheduling transportation or other export-related activities. 

If PACS has already determined that your operation meets the requirements under SOE, and all information is complete on your NOPIC Request Form, turnaround time for issuing your NOP Import Certificate should be approximately 3 business days. Please allow more time for initial NOPIC requests, as PACS must assess related labels before adding your products to the Organic Integrity Database (OID). 

NOPICs can span a length of time from one day, up to 12 months with an option to extend the certificate (after 12 months) for an additional 6 months to a total of 18 months. 

PACS determines the duration of a NOPIC using risk-based criteria, which considers a variety of factors. 

If your operation has a history of missing documentation, non-conformities, poor communication with PACS, NOPICs will be issued for a short period. Even if your enterprise has an immaculate history with PACS, if you are handling high risk crops or products, or your supply chain is complex or has known vulnerabilities for fraud, your NOPIC may be issued for a short duration of time. 

Yes. Multiple products can be listed on a NOPIC provided they all have the same Harmonized Tariff Code, and all other information on the NOPIC applies to all products (importer, handlers, etc). For example, raisin bread and whole wheat bread can be listed on the same import certificate, but waffles require a separate certificate. 

No. You must submit the exact 10-digit code on your NOPIC Request Form. You can look up the correct code on the US Harmonized Tariff Schedule.

• Traceability documentation from suppliers including organic certificates, invoices, lot numbers/identification, shipping information/documentation.
• Inventory records that include the average annual production of each product, inventory level at time of NOPIC request, inventory levels at expiry date of NOPIC.
• Estimated net weight over entire duration of NOPIC (all shipments); actual net weight of shipments over the entire duration of the NOPIC. 
• Labels for all products exported.
• Shipping details for all shipments. 
• Lot numbers for products on all shipments is preferred, though not mandatory. 

NOTE: PACS may initiate an unannounced inspection or desk audit to include the information listed above on short notice. These records should be compiled as soon as they are available, and ready for inspection throughout the year. Failure to provide requested documentation will be considered a non-conformity and may jeopardize the validity of an operation’s NOPICs.

Most of the information must be submitted before the NOPIC is issued - before or with your NOPIC Request Form. 

The actual net weight(s) for each shipment and ending inventory must be submitted near the expiry date of your NOPIC, while the NOPIC is still valid (no later than 1 week prior to expiry date). PACS will update the system with actual net weights before the NOPIC expires. 

NOP will be reconciling the information it receives from US Customs. Net weight reporting (to PACS) will be the responsibility of the export-operator.  

Production volume must also justify export volumes. So, operators must ensure that they have control systems in place for recording and reporting to PACS. 

Frequency of reporting to PACS will depend on various factors, not limited to the frequency of your shipments, the quality of information provided, and compliance history. For higher risk operations (with poor compliance or record-keeping history) reporting will be required more frequently and NOPICs will be issued for shorter periods of time. 

Your operation must have an Organic Fraud Prevention Plan (OFPP) in place by March 19th, 2024. Verification Officers will include this in their inspections. 

The purpose of an OFPP is to prevent fraud from happening. Prevention is more effective than catching fraudulent activities after the fact. This goal lies at the heart of the USDA’s Strengthening Organic Enforcement and is a critical element of strengthening the organic system across all jurisdictions. 

Organic Fraud Prevention Plans must be appropriate for the size and complexity of each organization. It is expected that a small crop operation will have a simpler OFPP than a large processor with a catalogue of multi-ingredient products.

It is completely acceptable to use elements derived from HACCP or other systems. Operations are not expected to duplicate work that has already been compiled and implemented.

For more information on OFPPs visit the USDA's Primers on SOE. There is a MOOC (Massive Open Online Course) on this topic available for free. The Organic Trade Association (OTA) also offers an Organic Fraud Prevention Program for a fee. 

Yes. The importer can be a non-US-resident. 

The importer of record who is filing the entry with US Customs is the importer you should list on your NOPIC. 

Generally, no. Travel strictly across the USA does not require an import certificate. You would not file an entry into the US for these shipments with US Customs because the shipment is in transit (to Mexico). This includes those that are transloading (via customs-bonded warehouses), since these shipments do not enter the US stream of commerce, nor do they file paperwork for duties, taxes, tariffs, etc. These shipments are simply transiting the US.

USDA Global Organic Integrity Database (OID)

Information on USDA Strengthening Organic Enforcement Final Rule

USA Labeling Regulations 

Harmonized Tariff Schedule 

Organic Fraud Prevention:
MOOC (Massive Open Online Course)
Organic Trade Association (OTA) Organic Fraud Prevention Program