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Frequently Asked Questions

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The new Strengthening Organic Enforcement rule, the most substantial update to the National Organic Program in 20 years, has made many changes to the type of information that certifiers must collect from clients. Due to these changes, all certifiers have made updates to their Organic System Plan documents. QCS is requiring all clients to submit a complete OSP at their annual renewal in 2024.

Countries we work in: Bahamas, Dominican Republic, Ecuador, Guatemala, Indonesia, Jamaica, Panama, Turkey, United States of America, Virgin Islands (U.S.)

States we work in: Alabama, Arizona, Arkansas, California, Colorado, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, New Jersey, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, Wisconsin

Yes, we will do everything possible to accommodate your needs.

Yes. If you implement a specific trade practice that you want your consumers to know about, like the fact that your employees are not exposed to pesticides, that you pay your employees a living wage, or that your operation is powered through solar energy, we can certify you through our Specific Trade Practices program. Under our Specific Trade Practices program, QCS will certify up to 6 specific trade practices characteristic of your organic operation. You identify the trade practices that you wish QCS to certify, and we will include them in your regular audit and review. QCS will issue you a certificate listing the specific trade practices that we were able to verify.

Strengthening Organic Enforcement (SOE)

The Strengthening Organic (SOE) Rule is an update to the organic regulation put forth by the USDA National Organic Program. The published rule is the most significant change to the national organic standards since the creation of the regulation in 2000. The goal of the SOE final rule is to reduce fraud in the organic marketplace; strengthen oversight of organic producers, handlers, and certifiers; and improve USDA’s enforcement mechanisms.

Organic supply chains are continually getting more complex which leads to less transparency and therefore the opportunity for more fraud. SOE aims to protect organic integrity and bolster farmer and consumer confidence in the USDA organic seal by supporting strong organic control systems, improving farm-to-market traceability, increasing import oversight authority, and providing robust enforcement of the organic regulations. SOE is needed as a measure to continue ensuring organic integrity as organic supply chains evolve and develop.

As a USDA-accredited certifying agent, QCS is not allowed to provide consulting services about how to comply with organic regulations. However, QCS has a team of experts who can provide information and guidance, in addition to offering free online resources.

The Strengthening Organic (SOE) Rule was published on January 19, 2023, but operations – including both currently certified and newly impacted uncertified handlers of organic products, and uncertified operations that were previously not required to be certified but will be required to under the new rule – must meet all the requirements in the rule by March 19, 2024.

Many operations working in the organic industry will be impacted. All operations involved in organic production are encouraged to review the regulations.  

  • USDA-accredited certifying agents
  • Organic inspectors
  • Certified organic operations
  • Operations considering organic certification.
  • Producers
  • Processors
  • Brokers, traders, exporters, and importers who are not certified organic.
  • Businesses that import or trade organic products
  • Retailers that sell organic products

QCS has created a Simple Organic Handler Plan, as well as an adjusted fee schedule and fee payment form for importer, exporter, broker, and trader operations that will need to seek certification to be in compliance with this rule. 

You can access these forms in our Document Library.

To learn more about exemptions and what operations are required to seek certification under SOE, please review the Accredited Certifiers Association decision tree or the Organic Trade Association’s Are You SOE Ready? Quiz.

Under SOE, there’s a strong bias towards certification across organic supply chains to uphold the integrity of the organic label and ensure consumers are getting a final product they can trust. This requires “transparent supply chains, trusted interactions between businesses, and mechanisms to verify product legitimacy”, as the SOE preamble states. So even if your company doesn’t directly produce or take physical possession of organic products, verification and oversight of your activities matters, and you have an important role in creating and promoting transparent supply chains.

To learn more about exemptions and what operations are required to seek certification under SOE, please review the Accredited Certifiers Association decision tree or the Organic Trade Association’s Are You SOE Ready? Quiz.

You would be acting as an uncertified operation handling organic product; therefore, that product would be disqualified from continued certification downstream of your operation, meaning your buyers or downstream retailers could not represent or sell that product as organic. This also means your operation may be subject to compliance and enforcement actions from the NOP, including the possibility of civil penalties (fines). This is specified at 205.100(c).

To learn more about exemptions and what operations are required to seek certification under SOE, please review the Accredited Certifiers Association decision tree or the Organic Trade Association’s Are You SOE Ready? Quiz.

The National Organic Program has expressed a strong bias toward certification, even for operations that qualify for an exemption. It’s possible to have portions of your operation certified, while other portions are not, if you qualify for an exemption. It is important to remember that even exempt operations have recordkeeping requirements 205.101(i) to be compliant with organic regulations.

To learn more about exemptions and what operations are required to seek certification under SOE, please review the Accredited Certifiers Association decision tree or the Organic Trade Association’s Are You SOE Ready? Quiz.

We certify operations like this both under one single entity certification and under individual facility certifications depending on the site-specific details. Please reach out to our Client Care Specialist to explore your options.

Third-party warehouses will likely require organic certification, but that depends on what types of activities they conduct and what kinds of products move through the warehouses.

To learn more about exemptions and what operations are required to seek certification under SOE, please review the Accredited Certifiers Association decision tree or the Organic Trade Association’s Are You SOE Ready? Quiz.

Handlers in your supply chain that qualify for one of the narrow exemptions set forth in §205.101(a)-(h) should complete and submit an Exempt Handlers Affidavit. The NOP organic regulations require exempt handlers to keep records that document the activities, volume, and flow of organic product through their facility from receiving to shipping. Their records must be made available upon request (by certified organic operations in their supply chain, or the NOP) and all records described must be maintained for no less than 3 years. See 7 CFR §205.101(i).

Any operation that produces or handles products intended to be sold, labeled, or represented as USDA-NOP certified organic products must be certified. Currently all responsible parties are required to be certified, including all crop, livestock, handlers and processors. This includes co-packers. Starting in March 2024, private label brand owners will also be required to be certified.

Unless they qualify for an exemption (detailed in §205.101(a)-(h)), all handlers of certified organic products will need to be certified by the SOE implementation date of March 19, 2024. After that date, all organic products supplied by uncertified (non-exempt) operations would no longer be considered certified organic. Because that could adversely impact your business activities, we encourage you to discuss SOE-readiness directly with any uncertified handlers in your supply chain. It is important for all certified entities to ensure that their entire supply chain meets the organic regulatory requirements in order to ensure that their products maintain certified organic status. 

Yes, we are required to conduct an on-site inspection of all facilities each year that you are seeking certification.

The on-site inspection is used to verify the information in your Organic System Plan matches day-to-day activities. If your operation does not take physical possession of products, the inspection will cover and audit the records that you keep. If you warehouse any products, your inspection will also cover that facility. You should have all records of sales, inventory, incoming and outgoing shipments, organic certificates from suppliers, and any other documentation you have indicated in your Organic System Plan.

Sealed and tamper-evident means the contents are sealed in a manner where an attempt to break the seal, access the contents (including to take out or put in product), or reclose the package would be obvious. However, sealed and tamper-evident does not mean impermeable to gas and water.

For more information on sealed and tamper-evident packaging, see our resource for organic supply chain actors.

The SOE revision clarifies that the percentage of organic ingredients calculation in a multi-ingredient product is to be made at the time of formulation. For example, the ingredients in a baked product must be calculated before processing occurs. The previous rule required total net weight of the organic ingredients at formulation to be divided by the total net weight of the finished product.

Under SOE, operators are required to keep audit trail documentation sufficient to determine the source transfer of ownership and transportation of the organic product. All nonretail containers must be labeled with unique information that links the container to audit trail documentation. The name of the last certified operation to handle the product should be found in the audit trail documentation.

These are any records traceable back to the last certified operation; i.e., audit trail documentation. Audit trail documentation must be sufficient to identify the source, transfer of ownership, and last certified operation to handle the product. This includes: Bills of lading, manifests, transaction certificates, shipping records, delivery records, invoices, lot numbers, and other audit trail documents: chain of custody, tanker seals, wash tags, truck and trailer numbers, etc.

Shipping/storage containers must identify their contents as organic (unless organic label on product packaging is visible), and the container must display a unique identifier (lot number, etc) which ties the container and its contents to audit trail documentation and the last certified operation to handle the product.

Additionally, optional labeling information is no longer mentioned in the nonretail labeling requirements. Therefore, additional labeling information is unrestricted and left to the owner’s or packer’s discretion. 

For more guidance and resources regarding organic labeling, please view our Organic Labeling webpage.

Retail labels are found in retail settings on individual items or packages. On retail labels, the organic certifier must be identified on the information panel, right below the information identifying the farm, manufacturer, or distributor. If the packaged product has more than one ingredient, then an ingredient statement is required, and that ingredient statement must identify each organic ingredient as organic. Unpackaged organic products in retail settings are not required to display any specific information, although the farmer or retailer can choose to display organic claims and can utilize the USDA organic seal or the certifier seal.

Non-retail labels are found on nonretail containers used specifically for shipping or storage of raw or processed agricultural products and do not display Price Look-up Codes or Certified Organic By statements, but instead may contain a lot number identifying where the bulk product came from, or some other traceability identifier. Non-retail containers (where nonretail labels are found) typically house products in bulk form or as palleted/master cases of a product in packaged form, and retail customers/consumers never interface with them.

For more guidance and resources regarding organic labeling, please view our Organic Labeling webpage.

An Organic Fraud Prevention Plan (or OFPP) is the plan that producers and handlers design as part of their Organic System Plan to outline the vulnerabilities and mitigation strategies for preventing organic fraud in their supply chain.

For more information on this topic, check out our Organic Fraud Prevention Plan page.


An Organic System Plan (OSP) is, simply put, a document that describes all aspects of your operation that are required to verify compliance with organic standards. This includes your operation name, location, facilities, products, and production practices. It can seem daunting to make one from scratch – luckily, QCS’s application for organic certification is a fillable Organic System Plan. So, by filling out our application, you are completing an OSP. This document will eliminate the guesswork and guide you through the organic standards, step-by-step! 

Completing the OSP will take some time and may seem overwhelming. If you have questions about how to fill out your OSP at any time in your application process, you can schedule a free information session with our Client Care Specialist.

You can view and download our OSPs in our Document Library. Choose the OSP that is relevant to your operation. Your options are:

  • Organic Grower Plan
  • Organic Livestock Plan
  • Organic Handler/Processor Plan
  • Simple Organic Handler Plan (broker, trader, importer, or exporter)
  • Organic Restaurant-Handler Plan
  • Organic Retail Plan
  • Organic Aquaculture Plan
  • Organic Apiculture Plan
  • Organic Wild Crop Plan

We strive to offer the best timeline for new clients and recommend planning accordingly based on your operational needs. Our standard timeline for certification is 3–4 months. This timeline considers all of our existing clients’ needs, as well as our current administrative capacity for new clients.

Upon the approval of a completed Expedited Service Request, we do offer expedited certification for an additional cost. The expedited timelines are for either 30–40 working days or 15–20 working days. 

We are proud to offer competitive rates for our certification services. The annual cost for certification breaks down into two parts: certification fees and inspection cost.

Certification fees are based on the annual gross sales of organic products for your operation (for new operations, we will accept a projection for your first year if you do not have actual sales yet). Inspection costs are based on the relative simplicity to complexity of your operation. Essentially, this equates to the amount of time the inspector will spend on the inspection.

Upon submitting your application, you will submit your certification fee as well as a deposit towards inspection (plus any additional fees such as on-farm processing, international verifications, expedited service fees, etc).  Any additional inspection fees will be charged after the inspection is complete.

You can find our fee schedules in our Document Library.

You’ll need to submit a completed Fee Payment Form and pay certification fees at the time you submit your application. The fee payment forms, listed below, are interactive check-list versions of the fee structures that allow you to calculate your certification fee total. Fees may be paid online or by mail.

How to Make an Online Payment:

  • make payments at www.qcsinfo.org/payment 
  • first-time applicants: type “NEW” along with your business name in the “Invoice Number(s)” field on our online payment webpage.

How to Pay by Mail:

  • please make checks made payable to Quality Certification Services
  • mail checks to 5700 SW 34th Street, Suite 349, Gainesville, FL 32608 USA.

Fee Payment Forms:

You can find the following fee payment forms in our Document Library.

  • Grower/Livestock Options 1 & 4 (Standard Producer or University/Research)
  • Grower/Livestock Option 2 (Multi-Unit Umbrella)
  • Grower/Livestock Option 3 (Dairy)
  • Handler/Processor Options 1 & 3 (Basic Handler or Contract Processor)
  • Simple Handler
  • Retail/Restaurant
  • Aquaculture

For Growers: Your land is eligible for crop certification if there have been no prohibited substances applied within the last 36 contiguous months. You must be able to provide records proving that no prohibited substances applied in that period. This is covered in OGP 3C: Previous Land Use Affirmation. If you have not had management of the land for any part of the previous 36 months, the previous land manager will need to fill out OGP 3C for the portion of time they had management of the land. 

For Livestock Meat/Dairy/Eggs: For dairy and beef cattle that are not currently certified, the herd is eligible for a one-time transition period of 12 months. You can find the specifics of transitioning a herd here. For calves, if the mother has been under organic management practices for the last third of gestation, the calf is eligible for organic certification upon birth. The calf must be managed organically from birth onwards. For poultry, chicks must be under organic management starting 24 hours after hatching. For eggs, they must come from certified birds. In addition to getting your herd or flock certified, the land of your operation must also be certified organic. The same rules for grower certification eligibility apply to fields used for organic livestock production.  

For Processors: For multi-ingredient products, a good rule to follow is “organic input equals organic output.” All single ingredients must come from certified organic operations; you must retain copies of the organic certificates from each supplier. For a multi-ingredient product, at least 95% of the ingredients (excluding water and salt) must be certified organic for the final product to be considered organic.  

As stated in 7 CFR 205.501(a)(11)(iv) as part of QCS’s obligation as a certifying body under the National Organic Program (NOP), we cannot offer consulting services. A good way to think about this is that we can tell you the “what,” but not the “how.” For example, we can tell you the regulations and rules about labels; we cannot tell you exactly how your labels should look for your specific products.

If you would like help with how to implement regulations specific to your operation, you have the option to work with an organic consultant. Organic consultants are not certification bodies, so they can offer you specific advice for your operation. You are not required to work with a consultant to get organic certification. It is yet another resource that is available to you as you work towards or continue certification. 

QCS maintains a list of organic consultants that you can view here.

No, QCS representatives are not allowed to consult and/or advise farmers on how to structure their Organic Grower Plan or provide any personalized information/recommendations on how to remain in compliance with USDA Regulations. QCS is only able to inform a farmer if their proposed plan is in compliance with the organic regulations.

Yes. Our Organic Grower Plan includes a portion that covers different types of soilless growing methods. 

You can find our Organic Grower Plan in our Document Library.

There are currently no guidelines in the National Organic Program that outline rules for certifying seafood. QCS does have a Private Aquaculture Standard and Organic Aquaculture Plan. You can view and download these documents, as well as the related fee structure and fee payment form, in our Document Library.

Depending on the type of operation you have, you can qualify for various food safety schemes. Please see our aquaponic food safety page for more information. 

As per 7 CFR 205.103(a)(b) the type of recordkeeping system you use in your operation is entirely up to you. It must be clear enough to verify compliance and traceability; usable by everyone in your operation to use it daily or as needed; and accessible for planned and unannounced inspections. Records are integral to organic certification. Clarity, consistency, and accessibility are more important than any fancy system. The rule is specifically written so that recordkeeping systems can be adapted to an individual operation’s needs.  

QCS does not require an operation to use any specific record-keeping template. We do, however, offer example templates as free resources in case they’re helpful to you. View these below:

You can find more resources and tip-sheets on the  NCAT-ATTRA Organic Farming website.

The NOP offers great advice here on record-keeping requirements and typical example records:


The USDA also offers this extensive explanation of appropriate documentation:


as well as a number of record-keeping templates:


For guidance and resources regarding organic labeling, please view our Organic Labeling webpage.

The Ohio Ecological Food and Farm Association (OEFFA) has a great tip sheet for labeling advice:


The NOP also offers an extensive slide show on labeling regulations and associated information:


Labeling Organic Products | Agricultural Marketing Service (usda.gov)

Labeling Packaged Products under the National Organic Standards

eCFR :: 7 CFR Part 205 Subpart D — Labels, Labeling, and Market Information

All of them! Please plan to send in all retail and non-retail labels for our review. We will accept your copacker labels as records, but we will not review them as that is the responsibility of the copacker’s certifier.

Labeling resources:

Inspections are generally scheduled once per certification cycle. Once the Inspections Department has scheduled an inspection window, your inspector will reach out directly to finalize a day and time. All certified operations must be inspected at least once per calendar year. It is also possible that any client could have an unannounced inspection. Inspection scheduling is dependent upon many factors and as a result the timing of your inspection may be different from one year to the next.

If your operation is applying for certification for the first time, it is important to communicate to your inspector when you will begin production. For crop operations, inspectors must see at least one crop in production or a follow up inspection must be scheduled and paid for by the client.

The best place to look for the complete list is in the Code of Federal Regulations: The National List of Allowed and Prohibited Substances. This covers all inputs for all scopes that are allowed or prohibited in organic production. The Organic Material Review Institute (OMRI) is also a great resource for products that are approved for use in organic farming. Please note: always consult your certifier before you apply a new input in your operation, even if it is OMRI listed or listed as “allowed” on the National List.   

Inputs that are reviewed and listed by reputable independent institutions may be acceptable if confirmed against the NOP National List. QCS accepts third-party material approvals for use under the USDA National Organic Program from the following material review organizations:

– California Department of Food and Agriculture (CDFA).

– Organic Material Review Institute (OMRI)

– Pennsylvania Certified Organic (PCO)

– Washington State Department of Agriculture (WSDA)

All third-party approved inputs can be found in the Intact Input database.

A master list of inputs currently recognized by QCS can be found by logging in to the QCS Client Portal. If an input is not found on this list, it still can be requested for review by the QCS Materials Team.

Inputs can have various statuses in our system. The negative statuses are “Dropped”, “Discontinued”, “Insufficient info” or “Prohibited.” These are the statuses that indicate that an input is not/no longer approved for use in organic production.

Inputs with a Dropped status are materials that have been reviewed and approved in the past, but the review is no longer valid. Inputs can be dropped if they are no longer registered with a material review organization. Having a Dropped status does not mean an input contains prohibited substances. Some dropped inputs will have a Use-By Date that is typically 18 months from the original drop date. Reviewers should notify clients of this use-by date when a material is dropped. Dropped inputs may not be added as new inputs to a client’s approved input list.

Inputs with a Discontinued status have been dropped by QCS or a material review organization because the product is no longer manufactured, or the manufacturer has gone out of business. Inputs with a Discontinued status will not have a Use-By Date. These materials may be used indefinitely by clients with the product already on their inputs list.  Discontinued inputs may not be added as new inputs to a client’s input list.

Inputs with an Insufficient Info status have been reviewed by QCS and the reviewer was not able to gather sufficient information to complete the review (manufacturer was unwilling to cooperate, manufacturer did not respond to requests for information, etc,). Both new reviews and products under re-review can be given an Insufficient Info status. Having an Insufficient Info status does not mean an input contains prohibited substances, only that we could not verify the compliance of all ingredients in the input. NEW inputs with an Insufficient Info status will not have a Use-By Date and they are not allowed for use in organic production. Reviewers may ask the client to obtain information from the manufacturer if the client is adamant about wanting to use the input. Previously approved inputs undergoing re-review with an Insufficient Info status will have an 18-month Use-By Date from the date of the status change. Insufficient Info inputs may not be added as new inputs to a client’s input list.

Inputs with a Prohibited status are either not in compliance with the NOP regulations as generally defined at §205.105 or with the EU regulations as defined at EC No 834/2007 and are therefore not allowed for use in organic production. Prohibited inputs do not have a use-by date and reviewers should alert clients to discontinue use immediately if they find a prohibited input on their Input List.

Yes, the NOP requires an organic operation to maintain up-to-date Organic Grower Plan that includes a list of each substance to be used as a production or handling input. Contacting QCS before using a new input is always encouraged. If a producer uses an input without prior approval, they are assuming the risk of applying a substance that may not be allowed in organic production.

Noncompliances are issued when a practice or input application does not comply with NOP regulations, regardless of whether or not the farmer is aware that the practice is in violation of the NOP rules. This process is designed to help us identify issues on your farm before they compromise the organic integrity of your product. We view noncompliances as an opportunity for the farm to make improvements to its organic grower plan and overall operation. When these improvements are laid out in a Corrective Action Plan, which illustrates who, what, when, and how the issue will be resolved and what preventative measures are in place to ensure the issue won’t repeat, noncompliances are then resolved by QCS. A noncompliance does not negate an operation’s organic certificate, and the operation can continue on with normal organic sales. If the operation does not resolve the noncompliance within the timeframe given by their QCS reviewer, then the compliance issue will be elevated to a proposed suspension. View our Non-Compliance Resource for more information.

A minor noncompliance is also an opportunity for the operation to improve their organic grower plan. A minor noncompliance is used for lower risk issues that must be resolved, but in a less pressing timeframe. If issued a minor noncompliance during your renewal cycle, the operation does not have to provide evidence that the minor NC was resolved until the following renewal cycle in the renewal application. If unsure of when to resolve any kind of compliance issues, please reach out to your most recent reviewer. View our Minor Non-Compliance Resource for more information.

Minor noncompliances are issued for noncompliant practices that:

  • Indicate no systemic failure in OSP design or implementation and;
  • Can be easily corrected without the need for a corrective action plan.

As well as minor inconsistencies or omissions in records that:

  • Indicate no systemic failure in OSP design or implementation and;
  • Can be easily corrected without the need for a corrective action plan.

QCS must receive a written description of actions taken to correct the minor noncompliance(s) with the annual renewal application for the following certification cycle. QCS will verify the implementation of corrective actions during the annual inspection.View our Minor Non-Compliance Resource for more information.

Noncompliances are issued for noncompliant practices that:

  • Indicate no systemic failure in OSP design or implementation but;
  • Are significant enough in nature or in scope to require a corrective action plan to ensure and verify compliance.

As well as inconsistencies or omissions in records that:

  • Indicate no systemic failure in OSP design or implementation but;
  • Are significant enough in nature or in scope to require a corrective action plan to ensure and verify compliance.

QCS must receive a corrective action plan no later than one month after the noncompliance is issued. Corrective action plans include the following information:

  1. How has the noncompliance been corrected, including actions already taken?
  2. How will the operation prevent recurrence of the same noncompliance in the future?
  3. Supporting documentation as evidence that corrective actions have been implemented;
  4. If applicable, any additional corrective actions that will be taken in the future, and the timeframe.

Alternately, an operation may rebut the noncompliance by submitting a rebuttal with evidence to support the rebuttal no later than the aforementioned date. View our Non-Compliance Resource for more information.

Your corrective action plan should describe a verifiable action that, when implemented, prevents a recurrence of the violation for which the NC was issued. The plan should provide documented evidence showing how the action(s) described will effectively prevent a recurrence, such as new training procedures for employees, new record keeping practices to track ongoing monitoring of compliance, updated manuals or checklists, etc. Please make sure your plan answers who, what, when, where, and how will this issue be resolved and prevented. This Corrective Action Template should be completed and submitted to QCS.

Certificates and Product Verification Forms are issued at the close of initial review, unless your operation has been designated to go direct to inspection. If this is the case, your updated cert docs will be issued at final review.

If there have been operational updates, such as new land or crops, that were viewed at inspection, an updated Product Verification form documenting these changes will also be issued at final review. If your wholesale company needs evidence that your operation is still certified, please request that your Client Project Coordinator send you a letter of good standing.

Your organic certificate never expires; however, certificates are valid until surrendered by the organic operation or until suspended or revoked by QCS, the State organic program’s governing official, or the USDA.

Certificates do include an anniversary date which is when application renewal materials are due.

No, but this is a goal for the coming years. While the regulation determines compliance, we as a certifier determine the best practices to help us determine if your operation has the potential to be compliant. As of now, our system is to communicate these best practices to clients individually as they arise.

Sometimes email service providers can incorrectly label correspondence from QCS as “spam.” To make sure that all correspondence is received timely, operations should mark QCS as an approved sender in their email preferences. For more details on how to add email addresses to your safe sender list, please read:


Your Certification Project Coordinator (CPC) is your primary point of contact for renewal documents and invoices. Your most recent crop reviewer can provide technical assistance as needed. If you are not able to determine who your most recent reviewer was, please contact your CPC and ask them to connect you with your most recent reviewer. The reviewer changes from year to year to ensure that we have many technical reviewers assessing your organic system plan for compliance.

Organic Crops

To add a crop to your PVF, QCS will need a purchase invoice and copy of seed tag/label to confirm the seeds are certified organic. If seeds are not organic, please also send the non-GMO and untreated statement (may be on the seed packet), and documentation of the commercial availability search.

5029.pdf (usda.gov)

A great place to start your search for organic seeds and planting stock is the website Beginning Farmers 

If seeds or planting stock are not commercially available for the crop you want to grow, you will need to show records of three attempts to source the seeds from different businesses. If none of the three businesses have commercially available seeds or planting stock, you may use non-GMO seeds for all perennial plants. All seedlings must be managed organically at all points going forward. Non-GMO conventionally grown tree planting stock must be under organic management for a minimum of 12 months before the fruit from that tree can be considered organic. Annual seeds and microgreens must be grown from certified organic seeds. Please refer to CFR 205.204(a) for more further information.  

Yes and no. If you are growing hemp with a THC content under 0.3%, then yes. It is considered hemp and is protected under federal law. If your operation is in a state where hemp production is legal, you will need to submit your state license that identifies your operation as an approved hemp grower. If you are growing cannabis with a THC content over 0.3%, it is not protected under federal law. Even if it is legal in your state to grow cannabis with a THC content over 0.3%, it is not eligible for USDA Organic Certification.

Yes! In order to ensure organic integrity, you must maintain full control of the storage unit or warehouse in which your crops are being stored. And you will need to fill out a warehouse affidavit form. Contact your most recent crop reviewer, and they will provide you with the necessary documentation. If your off-farm storage needs to be added to your entity’s product verification form, the site must be inspected first.

Planting before inspection is encouraged because the inspector will have the opportunity to view the crop in the field. This will allow them to get a better idea of how the Organic System Plan will be implemented on the new land. This means it is also acceptable to plant the land before it is added to the organic certificate.

Harvest and sale may not take place before inspection or before it is added to the organic certificate if the crop is to be marketed as “organic”. In some cases, harvest may be authorized after inspection takes place but before the final review is completed. In such situations, the crop may be stored until the review is complete and then may be sold as organic. Please discuss this option with your most recent crop reviewer.

Yes, all marketing materials that mention a farm’s certified organic status must be approved prior to use. This includes but is not limited to farmer’s market banners, pamphlets and websites. OGP 14 should be updated with the types of marketing materials used.

Treated lumber is not allowed for use on certified organic land. If treated lumber has been installed on land within the past three years, a sufficient buffer zone would need to be established between the treated lumber and any nearby growing area to prevent contamination.

An operation’s use of lumber treated with prohibited materials prior to organic certification does not affect an operation’s timeframe for achieving certification. Section 205.206 prohibits use of lumber treated with prohibited materials in new installations and for replacement purposes in contact with soil or livestock. This requirement applies to operations already certified. Thus, lumber treated with prohibited materials and installed or used for replacement purposes prior to the operation achieving certification is permitted, provided there is no contact with crops.

NOP 5036 Draft Guidance on Treated Lumber (usda.gov)

Power poles vs raised garden/greenhouse

Pressure-Treated Wood: Organic and Natural Alternatives – ATTRA – Sustainable Agriculture (ncat.org)

NOP 5036 Draft Guidance on Treated Lumber (usda.gov)

The USDA organic regulations at section 205.206 state that treated lumber must not contact soil or livestock, but do not discuss contact with crops. However, USDA organic regulations at section 205.201 require organic producers to describe in their organic system plan how they prevent contact of organic production with prohibited substances. Contact between crops, soil or livestock and prohibited materials contained in or on treated lumber must be prevented.

Transitional produce needs to be labeled and sold as conventional. You can tell customers the farm or land is in transition for organic production, but you cannot label or sell as organic. Starting in the near future, QCS will offer a transitional certified logo which will differentiate produce from the conventional options while still maintaining the integrity of organic. If you are interested in learning more our transitional program, please reach out to the most recent reviewer who has contacted you to discuss this service.

The USDA offers this advice on buffer zones:


QCS maintains an aerial spray buffer zone policy that states that an organic crop must have a 300ft buffer from the spray zone.

6 Buffer Zones FINAL RGK V2.pdf (usda.gov)

Equivalencies can be added by completing the OGP section of the desired equivalency and paying the corresponding fee. Please reach out to your client project coordinator (CPC) and they will provide you with the documentation and send you the invoice. From there it will be reviewed and added to your organic system plan.

New parcels will ideally be added when you are renewing your organic certification, however they can also be added out-of-cycle by submitting an Additional Lands Application and paying the associated fee. You will need to indicate on your renewal form that changes are being made to your organic grower plan, along with a brief description of the change(s), such as the number and names of new parcels being requested for certification. Along with this renewal, you will also need to submit an updated map as well as OGP3 “Parcel Information” form for each new parcel, including a land use history dating back at least three years in order to determine organic eligibility. If you cannot provide a land use history for the parcel that dates back that far, then the parcel can be assessed for transitional status. This status would apply until your farm has had full management control of the parcel for three years (assuming no prohibited substances had been applied during that transitional period).

Simple on-farm processing is an add-on service given to crop and wild crop clients who practice extremely simple processing with ingredients grown on farm. This allows these operations to continue with their simple processing procedures without needing to fill out an Organic Handler Plan and pay for an additional service. An operation will be billed when simple processing activities in the On-Farm Processing section of OGP 13 meet all of the criteria described below.

To qualify as on-farm processing, activities must:

  • Be conducted by the same legal business entity under the same ownership and management as the farm operation;
  • Occur at a site that is described in the operation’s OSP and can be inspected with the crop production parcel(s);
  • Consist entirely of certified organic ingredients/products that are produced on that farm;
  • Consist of simple processing only, including but not limited to: Curing, drying, dehydrating, cutting, grinding, shelling, de-hulling, de-pulping, ripening, sanitizing, mixing raw agricultural ingredients, crushing to extract oil; use of handling equipment such as a sorting machine, shaker table, or gravity separator; and/or packaging raw agricultural products into retail containers using a packing line or packing equipment;
  • Completely describe on-farm processing activities in the OSP in sufficient detail to evaluate compliance;
  • Operation must pay the on-farm processing fee.

The on-farm processing activities must NOT

  • Include any complex processing activities such as baking, churning, extracting, slaughtering, distilling, eviscerating, preserving, freezing, canning, jarring, and/or aseptic packaging.
  • Use any ingredients that are not produced on-farm.

A certified organic farm that intends to purchase organic produce from other certified organic farms must complete the Farm Retail section of the OGP to determine exemption eligibility. If this applies to your operation, please contact your most recent reviewer.

No. Having your soil tested is not a requirement to apply for organic certification.

Keep in mind: During inspection, your inspector may take soil samples as part of the audit.

Once you are certified, you will be required to submit soil test results if you want to apply micronutrients. Soil test results will need to show the specific micronutrient deficiency you want to correct.

For allowed use of synthetic micronutrients, a documented deficiency of such micronutrients must be provided to QCS in the form of a soil or plant tissue test, photo evidence, or by some other verifiable means. Deficiency evidence must be documented within three years of the current date.

Water tests are typically provided by farmers using well water or surface water for irrigation and post-harvest washing to demonstrate there are no contaminants or pathogens in the water source. This isn’t as necessary for farmers using municipal water since public water systems are generally required to sample and test for contamination on a regular basis. Water tests, at a minimum, must test for total coliform and E.coli levels and must be documented within three years of the current date.

The inspector’s role is to verify that your grower plan is an accurate portrayal of your farm activities. They make observations of what they see but do not make any compliance decisions. They share this information with the certifier and from there, we determine if your operation is in compliance with the relevant regulations. In order to assist with this process, be ready to show the inspector:

    1. Your parcel(s)
    2. Storage, facilities, equipment, and inputs
    3. Receipts for inputs (including fertilizers, pesticides, seeds, transplants, et.)
    4. Input application records
    5. Equipment cleaning records, clean truck affidavits (if applicable)
    6. Seed information
    7. Field activity information
    8. Harvest Records
    9. Sales Records
    10. Copies of any labels or other marketing materials you have used

For more details on this process and what the inspector will be evaluating, you can refer to section 3.4 of the NOP Handout 2601:

Instruction: The Organic Certification Process or this USDA pre-inspection questionnaire.

Obtaining the optimum carbon-nitrogen ratio in a compost pile is important for sustaining soil microbes that decompose organic matter and then release nutrients like N, phosphorous and zinc in forms available for crops to uptake. This ratio directly impacts how quickly organic matter breaks down and how much nitrogen is recycled from the decomposed matter. The Urban Worm Company provides a helpful “calculator” on their website for determining the proper carbon to nitrogen ratio for compost piles given the ingredients used:


Carbon and Nitrogen Content (ucanr.edu)

Food Safety | G.A.P.

Supermarkets, retailers, food service business and consumers everywhere are looking for food that is produced responsibly in ecologically sound conditions. This worldwide accepted certification enables producers and brand owners to provide consumers with assurance of the safe production and traceable marketing of food while protecting scarce resources. Individual producers or producer groups may be certified.

You should find out directly from your buyer(s) what standards they will accept. Some buyers will only accept GFSI recognized standards such as GLOBALG.A.P.

The importance is that your certificate should be accepted by all buyers worldwide. The motto is “once certified, accepted everywhere.” For more information about GFSI click here.

You may download the application form as well as other informative documents from our website. Fill out the application and return it to qcs@qcsinfo.org. A QCS representative will send you the cost estimate and the service contract agreement once the application is received and checked.

No, QCS is a third party accredited certification body and we cannot help you in that regard as we must maintain complete independence and impartiality throughout the certification process. This brings integrity, trust, and recognition to your certificate. However, if needed, you may seek advice elsewhere (e.g. consultants, growers associations, etc.).

This varies according to each individual situation. However, if you meet all certification requirements, from the time QCS receives a signed service contract, payment, and conducts the on-site audit the timeline should be less than 15 days. The entire process timeline should be less than 30 days.

The certificate is valid for 12 months from the date of the certification decision. Let’s say your on-site audit was conducted on August 15th, 2020, and the review of your file and positive certification decision was made on August 27th,2020. In this case, your certificate would show a valid from date of August 27th, 2014, and a valid to date of August 26th, 2021.

You must have conducted a self-assessment to check compliance with the standard before the day of the audit. You may download and use the self-audit checklist available at our website.

You must have documents and records available on-site demonstrating compliance with the standard for at least the past 90 days on the day of the audit.

You must schedule your audit at a time when all of your production processes including harvesting may be audited for the products you want to certify.

If your harvest process is different for your different crops the answer is yes as we must audit all of your production processes initially. For a renewal audit there may be some flexibility on a case-by-case basis.

You should take corrective actions to bring your operation to a level of compliance where you think you will at least meet the minimum acceptance criteria as stated in the standard document. Doing this will improve your chance to obtain certification when you schedule a formal on-site audit.

The main difference is that the Produce Harmonized GAP Standards are not recognized by the Global Food Safety Initiative (GFSI) while the GLOBALG.A.P. Standards for produce are GFSI recognized.

The Integrated Farm Assurance (IFA) standard for Fruit and Vegetables (F&V) is GLOBALG.A.P.’s flagship standard with a holistic approach to farm assurance including food safety, environment and biodiversity, workers welfare, and traceability requirements. All IFA standards are applicable and accepted worldwide.

Produce Safety Assurance (PSA) is designed for regions where producers and their customers require only a food safety solution, the new Produce Safety Assurance Standard V5. based on the GLOBALG.A.P. Integrated Farm Assurance (IFA) Standard and consists of only the food safety elements.

Harmonized Produce Safety Standard (HPSS) is designed for fruit and vegetable producers in the US or selling into the US market.  It covers all stages of production, from pre-harvest activities such as soil management and plant protection product application to post-harvest produce handling, packing and storing. This standard only focuses on food safety and traceability elements.

The Field Operations and Harvesting standard is applicable to produce growers including field packing and handling, and transportation from the field to storage or packing house.

The Post-Harvest Operation standard is applicable to packing houses handling fresh produce including storage, cooling, trimming, washing, and packing activities.

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