If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.
USOA Quality Policy
USOA provides professional, independent, and transparent review of materials and processes to determine their suitability for producing, processing, and handling organic food and fiber. The USOA Review Program is committed to maintaining a timely, courteous, accurate, transparent, and consistent approach throughout the program and on a day-to-day basis.
USOA’s mission is to support the growth and trust of the global organic community through expert, independent and transparent verification of input materials, and through education and technical assistance.
Introduction to USOA
The U.S Organic Association (USOA) is an organization that was founded to benefit the organic community and the general public. Its primary mission is to support the growth and trust of the global organic community through independent and transparent verification of input materials, and through education and technical assistance.
USOA is proud to promote organic standards that were independently developed by USOA and verifies said standards for USOA Organic Certification independent of any other organization or standards.
USOA administers its Review Program in a non-discriminatory manner. USOA considers applications for review of any input product that falls within the class categories described in the relevant USOA standards and does not discriminate against supplier applicants for any reason. USOA does not deny participation in or benefits of the USOA Review Program to any person because of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status and does not deny service based on the number of products already listed or the size of the applying company.
Policies to Safeguard Confidentiality and Impartiality
In order to conduct accurate and thorough reviews, USOA must access all pertinent information regarding each product. This includes the identity and source of every ingredient and the manufacturing process for all ingredients and the final product. Because the manufacturer or a third party may consider some of this information to be proprietary, USOA has developed policies and procedures for handling confidential business information.
All USOA staff, contractors, and other affiliated personnel are required to sign a confidentiality agreement, which is kept on file with USOA. By signing this agreement, USOA personnel agree to safeguard confidential information according to written procedures, and not to use this information for any purpose other than their work with USOA. Only personnel who have signed a confidentiality agreement with USOA are authorized to access confidential information.
USOA recognizes the importance of ensuring the confidentiality of information submitted during the course of a product review. USOA considers all information submitted to be confidential
Scope of the Program
USOA Review Program services are available to all applicants whose products fall within the Scope as defined below. However, USOA may decline to review products affected by currently unresolved policy or standards issues. USOA reviews input products and does not review devices or services. USOA lists products according to use and confines its review requirements, evaluations, and decision making to those matters specifically related to the particular use for which a product has applied.
USOA’s role is advisory, and USOA makes no claim that its recommendations and opinions coincide with all applicable governmental or organizational standards. Interpretation of the laws governing organic production is the responsibility of the appropriate government agencies. USOA is not responsible for the loss of certification, loss of organic status, or other consequences for failure to comply with organic legal or certification standards. Final decisions regarding the acceptability of input products reside with the individual organic certification agents. Producers, processors and handlers with questions about the acceptability of use or any restrictions on use of a particular material should contact their certification agents or enforcement officials for information.
USOA assumes no liability or responsibility for delays in the materials review process, delay or denial of organic certification to any third party who has used a material pending USOA review, or for the subsequent denial or loss of organic certification of a third party that results from the use of a prohibited material.
Review Under USDA and Other Organic Standards
The USDA National Organic Standards (NOS) form the foundation of the USOA standards for input products intended for use in certified organic production in accordance with these standards. The NOS are the regulatory text administered by the USDA’s National Organic Program and found at 7 CFR Part 205. USOA may review products against additional standards that are described in more detail in the application materials.
USOA Listed suppliers pay supplier fees, product review fees, and renewal fees to cover the costs associated with the administration of the Review Program. See USOA’s website for a current fee schedule.
It is the applicant’s responsibility to prove compliance with USOA policy and standards. USOA cannot assume compliance in the absence of proof. The application forms are intended as tools for applicants to submit complete applications. However, additional information may be requested at USOA’s discretion. The application forms outline various documents and information that must accompany a product review application. Incomplete submissions result in delay of the product review and listing process. Review requirements are subject to change. USOA reserves the right to make reasonable changes to USOA application requirements as needed to ensure the thoroughness of the USOA review process.
Each applying product must have a unique name. To ensure clarity in the organic sector, USOA reserves the right to add additional identifiers to the product or company name for listing. All formulations sold under the applying product name must be submitted to USOA. Fees for alternate formulations can be found on the USOA website, and may apply for each organic standard requested.
Disclosure of Ingredients
USOA requires applicants to fully disclose all ingredients and their sources to USOA in order for products to be reviewed for listing. Ingredients not generally found on the product label must still be reviewed by USOA. Examples include but are not limited to: inert ingredients in registered pesticides; excipients in animal medications, vaccines and supplements; and carriers, diluents, flowing agents, and other incidental ingredients in food processing additives. USOA requires that all formula proportions and manufacturing processes be provided unless exemptions apply.
If a product contains another product as a component, all ingredients of that other product must be disclosed to USOA. If the component is already an USOA Listed product, source documentation may be sufficient.
All current and anticipated ingredient sources must be reported at the time of application, and the supplier must inform USOA of any change in an ingredient or its source after listing.
USOA staff evaluates the product application to see if the information is complete and complies with the relevant standards. If the product evaluation process indicates that additional information is needed to make an accurate determination as to a product’s conformance with the relevant standards, staff notifies the applicant of the additional information required with a deadline to receive the necessary documentation.
Decision Making Process
Staff provides the USOA Review Panels with the Findings of Fact and supporting documentation needed to review each product that has applied for USOA Listed status. Decisions are made by a Review Panel member or by majority vote of the Review Panel. The Review Panel uses USOA standards to evaluate products.
Documentation and Communication of Decisions
USOA seeks to notify applicants of their product’s status within one week after the Review Panel has made its decision. If the product has been assigned Allowed or Allowed with Restrictions status, the notification includes an USOA Listed certificate and information about the USOA Listed seal licensing policy. Suppliers of such products undergo annual renewals. Notification letters to applicants whose products have been assigned Allowed with Restrictions status also include text from the relevant USOA standards describing the use restrictions that apply to their product.
Repackaged products are USOA Listed products that are repackaged and marketed under a different product or company name, either by the original USOA Listed supplier or by another company, without modification to the original product. Suppliers applying for USOA listing of repackaged products are subject to the same application, initial review, and product evaluation procedures. See the USOA website for applicable review fees.
Based on staff review of application forms and documentation provided by the applicant, USOA makes a determination as to whether such products qualify as repackaged products as described in this section. Products that qualify as repackaged products are assigned the same USOA status as the original USOA Listed product.
If the original USOA Listed product is removed from an USOA Products List for any reason, repackaged products associated with the delisted product are affected.
Consent to Site Inspections
By signing the Supplier Agreement between USOA and the USOA supplier or applicant, suppliers agree to abide by all USOA policies. This includes consenting to inspection of the supplier’s offices and/or facilities by USOA inspectors. Site inspections may be announced or unannounced at USOA’s discretion. USOA arranges unannounced inspections when there is reason to believe this method might yield more valuable information for product reviewers and decision makers, or, as in the case of random surveillance inspections, to ensure that USOA Listed suppliers consistently maintain USOA compliant practices.
If USOA has reason to believe that an applicant or an USOA supplier has misrepresented their product, its ingredients, manufacturing process, or intended uses in the supplier’s or applicant’s communications with USOA, USOA will conduct an investigation. Such an investigation may lead to delisting of an USOA Listed product, or denial of USOA Listed status for an applying product if the product is found to be noncompliant with USOA standards, as well as delisting of all of the supplier’s currently listed products. Applicants or suppliers who are found to have misrepresented their products may not apply to USOA with a new product application for one year after the final resolution of the investigation. If USOA suffers any loss or liability as a result of misrepresentation of a product by an USOA Listed supplier or an applicant, USOA reserves the right to take legal action against that USOA Listed supplier or applicant.
Use of the USOA Listed Certificate and Seal
USOA Listed Certificates
USOA Listed certificates are issued to suppliers of products that have successfully completed the USOA product review process, and have been assigned an USOA status of either Allowed or Allowed with Restrictions. Certificates are valid for one year and must be renewed annually. Notwithstanding the annual renewals cycle, an USOA certificate may be revoked at any time.
USOA Listed certificates for products that have been delisted are void. Suppliers of currently USOA Listed products may display or reference only current, valid certificates for those products. Use of an expired, altered, or voided certificate is a violation of USOA policy.
The USOA Seals
The USOA seals are registered trademarks that USOA provides in electronic form to suppliers of USOA Listed products. Variation in or changes to the Seals are in violation of this policy. Suppliers with USOA Listed products can go online to: www.USOA.org/suppliers/seal to download the appropriate Seal.
Authorization to use an USOA seal is granted:
- To those companies whose names appear on the most current USOA Products List and/or on valid USOA Listed certificates.
- For use only with labels and formulations as reviewed by USOA for currently listed product names that appear on the most current USOA Products List USOA Listed certificates.
Authorization to use the Seal is extended to distributors of currently listed products so long as the USOA reviewed label is used, and both the product and company names appearing USOA certificates are also displayed.
Authority is not granted to suppliers to extend authorization to any other company to use the USOA seals under any other circumstances, such as for USOA Listed products that are private labeled and/or repackaged.
Authorization to use the USOA Listed seal is immediately withdrawn upon:
- Removal of the product and/or company name from the USOA Products Lists.
- Any unreported changes to previously reviewed labels and/or formulations.
Each product marketed as a distinct product must obtain USOA Listed status independent of any other product listing in order to use an USOA seal or make USOA Listed claims. Displaying the Seals in a way that could reasonably be thought to apply to a product that is not currently USOA Listed is in violation of USOA policy and trademark law. The product name and company name given on any product labels or in any advertising or promotional materials must match that which appears in the current USOA Products. Private labels or repackages of USOA Listed products require a separate application under USOA’s repackaged products policy before the supplier may promote the product as USOA Listed.
Third Party USOA Listed Claims and Ingredient Claims
It is ultimately the responsibility of the USOA Listed supplier of record to see that use of the USOA seal and USOA Listed claims in association with their product(s), including in promotional materials and on websites of distributors or other third parties, are in conformance with USOA policy. USOA Listed suppliers must be able to document a good faith effort to police third-party use of the Seal in association with their products.
Product labels or promotional materials for non-USOA Listed products that state or suggest that the product contains USOA Listed ingredients are in violation of USOA policy. Even if such statements are true, USOA considers them to be misleading because USOA has not reviewed and listed the final product.
USOA’s goal is to provide clear information to organic certifiers, organic producers, and organic handlers on the use of products and materials in their “Organic System Plans.” Labeling of products in a manner which easily confuses these potential users is not consistent with this goal. USOA will not list a product if it finds that the product’s label provides false or misleading information to potential users. If labels and marketing materials for an USOA Listed product contain or imply use instructions, at least one published use must be compliant with the USOA Listed class/category for that product. For products listed in Processing Use Classes, “labels and marketing materials” refers to all product labeling, including technical specification sheets, which together must contain sufficient information for the user to comply with the relevant organic standards and any use restrictions applied by USOA.
USOA requires that the product and company name shown on the label of an USOA Listed product and the product and company name as published in the USOA Products List match. USOA reserves the right to add additional qualifiers to product or company names in the product listing as necessary to ensure clarity in the organic sector. In some cases where names on labels may be interpreted to vary, repackaged product applications may be required. Labels must also include some form of contact information for the USOA Listed company (e.g., website, physical address, phone number, etc.).
Company or Product Ownership
USOA listings are not automatically transferable. If an USOA Listed company or product changes ownership, the new owners are responsible for notifying USOA upon completion of the transaction, and for providing proof of the ownership change. All appropriate forms and fees must be submitted to complete the change. Contact the USOA office for specific requirements. If a company or product is sold to another company, USOA will make a good faith effort to contact persons on the contact list from the old company to confirm the transfer. The new owners must also submit information to show that the manufacturing process and the ingredients are the same as in the previous owner’s product. If USOA determines that a substantive change has been made to the product, the new owner is required to submit a new complete product application packet and fee.
If the company’s name changes (not an ownership change), this change must be reported to USOA immediately. If a supplier wishes to market the same product under more than one company name, the supplier must submit a separate application and fee for each company name.
Company and Product Changes
USOA policy regarding company and product changes is intended to ensure that the USOA Products List contain the most current and accurate information available, and to determine whether any change made to an USOA Listed product will affect its USOA status. USOA Listed suppliers are responsible for notifying USOA in writing at least 60 days prior to release into the marketplace of any product affected by a change.
Suppliers must report to USOA any change to a product’s name immediately. If a supplier wishes to market the same product under more than one name, the supplier must submit a separate application and fee for each product name. Such products are considered Repackaged Products.
Suppliers must report any label change that is not strictly cosmetic to USOA immediately. If a new label suggests a substantial change to a product’s use or purpose, or makes new claims that are not substantiated by information in the USOA file, the product may undergo a product change review.
Monitoring Continued Conformance
USOA reserves the right to reconsider the status of an USOA Listed product at any time. USOA monitors continued conformance through the renewal process, product changes, inspections, sampling, investigations, and through both limited and ongoing compliance re-reviews. Product re-reviews are conducted for the reasons and according to the process described in this section.
Supplier working with USOA must agree to indemnify, defend and hold harmless USOA and its employees, directors, officers and agents from any costs, expenses, liabilities, demands, judgments, attorney’s fees or claims of any nature that:
- Arise out of or relate to the review of any product submitted to USOA or which are connected in any way with the performance of USOA’s responsibilities;
- Arise out of or relate to the sale, marketing, promotion and use of Supplier’s product; or
- Arise out of or relate to Supplier’s use of the USOA Marks.
USOA is proud to promote recognized scientific backed organic standards. All logos and likenesses represented by USOA Organic Certification are the property of USOA.
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