After the implementation of the Strengthening Organic Enforcement final rule on March 19, 2024, any organic agricultural product imported to the United States must be associated with a valid NOP Import Certificate, generated by the certifying agent of the final certified exporter sending the product to the United States.  This requirement applies to products certified as USDA organic or traded under an established equivalence arrangement.  Section §205.273 of the USDA organic regulations detail the requirements for imports to the United States.

Organic exporters certified by QCS must request a NOP Import Certificate prior to exporting organic products to the US by providing relevant details on the QCS NOP Import Certificate Request Form. You can find the Spanish version of this form here.  NOP Import Certificates must be requested for a specific volume of a single organic product that is listed on the operation’s Product Verification Form.  The certified organic exporter must time the request to allow sufficient time for QCS to verify its validity and generate the NOP Import Certificate, and for the exporter to deliver it to the importer or Customs broker before the CBP filing requirements for the product. The operator can export the entire volume listed on the NOP Import Certificate in a single shipment, or in multiple shipments within a specified period of time. 

QCS verifies the validity of the NOP Import Certificate request to ensure the product to be exported is certified organic and organic integrity is maintained.  Approved NOP Organic Certificates are generated within the Organic Integrity Database (OID).  Organic products may not be imported into the United States without an approved NOP Import Certificate.

The certified organic exporter provides the NOP Import Certificate to the U.S. importer.  The importer or their designated customs broker enters the NOP Import Certificate data into the U.S. Customs and Border Protection (CBP) Automated Commercial Environment (ACE) as part of its standard import filing process. 

Organic importers must have a documented organic control system to verify that organic products they receive are associated with a valid NOP Import Certificate and that they not been treated with a prohibited substance as a result of fumigation or treated with ionizing radiation. 

As certified organic products move from the exporting country into the United States, all entry documentation including, but not limited to bills of lading, bills of sale, commercial invoices, and packing lists must clearly state that the product is organic.  Exporting and importing operations must maintain records required under § 205.103.  This includes sufficient records to provide an audit trail to determine the source, type and quantity, transfer of ownership, and transportation of any agricultural product labeled as organic.