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.