Selling Organic Inputs to Organic Farmers
Fact Sheet | Selling Organic Inputs to Organic Farmers
NAVIGATING ORGANIC INPUT REGULATIONS
The biggest difference in selling products to organic farmers is the USDA Organic regulations. The USDA’s National Organic Program (NOP) is supported by federal regulations, which means there are real teeth behind the rules, and compliance is essential. Every input used on organic farms must be allowed for use. If the supplier or farmer mistakenly uses a prohibited substance, the farmer risks losing their organic certification, and that is a big blow to a farmer.
The NOP regulations, specifically the National List of Allowed and Prohibited Substances, is the starting place to determine whether a product is allowed for use in organics. Generally, non-synthetic substances (e.g., lime from a mined source) are allowed and synthetic substances (e.g., chemically-derived lime) are not allowed. However, there are exceptions. For example, arsenic is non-synthetic but prohibited, whereas magnesium sulfate fertilizer is derived from synthetic processes but allowed. So don’t make assumptions—take the time to read the regulations. A quick “Ctrl+F” search in the regulations can show if a substance is included in the regulations.
§ 205.600 Evaluation criteria for allowed and prohibited substances, methods, and ingredients.
Another reliable way to confirm if a new product is already allowed for use in organic agriculture is the Organic Materials Review Institute (OMRI), an international nonprofit organization. All products listed by OMRI are allowed for use under the USDA organic program.
Finally, just because a product says “organic” on the label does not mean it is approved in certified organic farming. The term “organic” has different meanings in agriculture versus chemistry. An organic substance, in the chemical sense, means that it is derived from carbon-based molecules (think compost). However, for an organic substance to be allowed for organic agriculture, it must be explicitly approved by the NOP or another certifying agency.
Visit the OMRI website to search their lists of allowed products.
“ALLOWED” vs “ALLOWED WITH RESTRICTIONS”
In some cases, a substance can be approved for one use and not another. The term for this is “allowed with restrictions”. The USDA’s organic regulations and the OMRI database indicate when and how the use of a substance is restricted.
EXAMPLE
Manure is allowed, but is restricted as to when it can be applied. The USDA regulation states that manure must be applied 90 or 120 days prior to harvest, depending on the crop and intended use (regulation: 7 CFR 205.203(c)(1))
Organic farming is based on natural systems and the benefits they provide. Farmers cannot apply an input simply because it is certified organic. Instead, they must use practices that reduce the need for inputs and demonstrate a need when inputs are used. Two key restrictions that are particularly relevant to input suppliers are preventive management and demonstrated deficiency.
Preventive Management
The preventive management requirement for pest, disease, and weed issues (regulation: 7 CFR 205.206(e)) states that before a product can be used, the farmer must first attempt to resolve the issue through agronomic practices.
EXAMPLE
If a farmer wants to apply a biofungicide for tar spot, they must demonstrate to their certifier that they tried cultural practices to prevent tar spot, and that the practices were insufficient. The responsibility is on the farmer to demonstrate the need for an input. When a supplier is making recommendations, be sure to remind farmers to document a demonstrated need.
Demonstrated Deficiency
The demonstrated deficiency requirement for micronutrient inputs (regulation: 7 CFR 205.601(j)(7)) states that in order to use micronutrient inputs, an organic farmer must document that they have a deficiency. This must be done for each micronutrient applied. Acceptable ways to document a deficiency include a soil test, plant tissue test, or other documented and verifiable method as approved by the certifying agent (such as observations of plant symptoms)
EXAMPLE
In the biofungicide example above, if the biofungicide product also contains trace minerals, then the farmer must document that they had a micronutrient deficiency AND that their preventive management practices were insufficient to control tar spot in their corn crop.
GETTING YOUR PRODUCT APPROVED FOR ORGANIC PRODUCTION
Selling inputs to organic farmers requires full transparency. No secret ingredients are allowed in organic production. While manufacturers do not have to list every ingredient on retail packaging, they must disclose all ingredients to the certifying agency.
There are two ways to make a product available to organic farmers. One option is for manufacturers to work directly with individual certifying agencies. In this instance, the manufacturer works with each farmer’s certifying agency to get the product approved. However, this can become burdensome when it involves working with several different certifying agencies.
The alternative is to submit the product for approval to one of the two main materials review organizations, OMRI or the Washington State Department of Agriculture. For a fee, these organizations review inputs for organic compliance and provide manufacturers a listing certificate that is widely accepted by organic certifiers.
SELLING SEED
Quality seed is crucial to organic farmers. Although organic farmers are generally required to use certified organic seed, there are exceptions (regulation: 7 CFR 205.204). However, all seed MUST be non-GMO and cannot be treated with a prohibited substance. Seed suppliers should be prepared to supply a statement certifying that the seed is non-GMO. Farmers must prove the source of their seed to their certifiers, so always indicate on the seed label or invoice whether the seed is certified organic, and specify any seed treatments applied (if any).
Treated, coated, or pelleted seed need to be clearly labeled as such on the seed bag or invoice. And the specific, full brand name of the coating product and the manufacturer’s name should be listed in the seed catalog or on the invoice. The treatment is part of what is being sold to the farmer and applied to the land, so growers must have that information for their organic certification records.
If you are selling organic seed, the seed needs to have been produced according to organic methods (regulation: 7 CFR 205.272(a), and 7 CFR 205.202(b)).
Research reported in this publication was supported by The Organic Center and the Foundation for Food & Agriculture Research under award number Grant ID: TOCFFAR-EXT-002. The content of this publication is solely the responsibility of the authors and does not necessarily represent the official views of The Organic Center and the Foundation for Food & Agriculture Research.