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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:
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:
How to Pay by Mail:
Fee Payment Forms:
You can find the following fee payment forms in our Document Library.
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:
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:
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.
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.
A list of approvable materials can be found here on the QCS website:
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:
As well as minor inconsistencies or omissions in records that:
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:
As well as inconsistencies or omissions in records that:
QCS must receive a corrective action plan no later than one month after the noncompliance is issued. Corrective action plans include the following information:
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.
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.
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.
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.
Power poles vs raised garden/greenhouse
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.
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:
The on-farm processing activities must NOT
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:
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:
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: