A significant limit to the continued growth and sustainability of the U.S. organic industry is a gap in domestic supply of organic ingredients and raw products. The growth of organic acreage in the U.S. has never kept pace with demand for organic products and increasing amounts of imports continue to fill the gap. Overcoming barriers to the growth in domestic organic acreage will require a multi-faceted and regionally oriented approach, and formally recognizing farms in transition to organic production through a federally administered process verification could be a piece to this puzzle.
For the past six months, OTA’s Transitional Task Force has provided industry stakeholder input on the merits of a transitional certification program and the framework necessary to ensure that such a program truly provides an on-ramp to organic without detracting from the organic label’s presence in the marketplace. The task force considered NOSB recommendations on transitional certification, current practices by accredited certification agents (ACAs) that offer transitional certification, and risks to the organic industry from the emergence of a new transitional market.
NOSB recommendation on labeling
In 2002, at its Spring meeting in Austin, TX, NOSB passed a recommendation regarding the labeling of transitional products. The recommendation details certain proposed definitions and proper use of the term “transitional” on products grown on farms in transition to organic production. The tenants of the NOSB recommendation provide much of the foundation for OTA’s transitional certification standards.
OTA’s Transitional Task Force
OTA’s Transitional Task Force looked at the potential benefits of transitional certification primarily from a producer-centric vantage point. The task force identified the need for transitional producers to have better access to support programs, and concluded that institutionalizing transitional certification could provide more streamlined access to USDA support programs like conservation incentives, appropriate crop insurance, and farm loan programs. When viewed from a buyer’s perspective, transitional certification appears as a partial answer to supply chain management by providing transparency in future growth of organic acreage that could facilitate appropriate business planning for buyers. Additionally, transitional certification creates the prospect of transitional markets where developing a market premium for transitional crops can incentivize producers to move towards organic, and can reduce the financial burden that a three-year transition period poses.
USDA’s Process Verified Program (PVP)
The success of a harmonized transitional certification program will require federal oversight of ACAs offering such a program to their clients. Transitional certification of farms and products under OTA’s transitional standards will utilize the oversight mechanisms provided by PVP to harmonize the verification process for transitional operations and provide added assurance that certified transitional operations were truly on their way to organic production. PVP allows for referencing existing federal standards, in this case the USDA organic regulations, and audits for accredited third-party certifiers much like NOP does for ACAs currently. The annual inspection requirement, federal oversight, and reference to the existing USDA organic regulations ensure that producers enrolled in this transitional certification program will set themselves up for a seamless transition into certified organic production.
Currently, anyone in the process of transitioning their operation can label their product as “transitional” without any mandatory oversight by a third party. There is currently no assurance that a crop labeled as “transitional” in the marketplace is coming from a producer who is actually planning to attain organic status, or that the crop has been grown on land free of prohibited substances for a minimum of a year. Formalizing transitional certification and, by extension, transitional labeling with PVP will add consistency to any transitional claim in the market, and assurance that the farms from which the products were sourced are on their way to organic certification.
Preventing ‘arrested transition’
Formalizing transitional certification and creating mechanisms to obtain premiums for these crops has the potential to incentivize ‘arrested transition’ where producers never fully achieve organic production but cycle in and out of a quasi-organic system to access the premium market. This is a serious concern, as transitional certification must act as a springboard to long-term, sustainable organic production, and not create an entirely new, distinct, and independent label and market. The flexibility of PVP allows for the design of a program to minimize the potential for ‘arrested transition’ to occur.
Since transition, by definition, is not a static state but rather a move towards organic, additional components must be built into any formalized transitional program. The framework for OTA’s transitional certification standards includes mechanisms to prevent ‘arrested transition’ by requiring a minimum of 12 months free of prohibited materials prior to eligibility for transitional status, by limiting the number of times an operation may enter and exit the transitional program, strict guidelines on labeling and limitations on the use of transitional logos or seals, and by the issuance of transitional certificates that expire once land has been free of prohibited substance for 36 months and is eligible for organic status.
OTA’s submission of its Transitional Certification Program standards to USDA will enable ACAs to apply for accreditation to the standard and offer this additional service to their clients as early as the 2016 crop year. We expect widespread adoption of OTA’s transitional standards to foster growth in transitional acreage, and, by extension, organic acreage. Transitional Certification will not act as a silver bullet in solving the organic industry’s supply shortage, but we do see it as a fundamental element of the comprehensive, collaborative plan to make organic production an attractive and attainable option for U.S. farmers. //