Going organic? Get certified or face fines.

Editor’s note: This letter is in response to our September 2023 cover story, “Dynamic organic.”

As an IGC that has been Certified Organic since the program’s inception in 1999, there are several additional factors that must be considered when evaluating offering organic products.

First, the NOP (National Organic Program) through the USDA permits the use of the term “organic” only for products that have been certified through an independent agency. There are certifying agents in almost every state. Certification is the essential, and required, part for utilizing the term “organic.” Those that certify and rely on organic products, many of them small farmers and growers, need to maintain the trust of consumers and value of buying an organic product.

Section 205.100 of the NOP Federal Regulations details the following: “…each operation or portion of an operation that produces or handles agricultural products intended to be sold, labeled, or represented as ‘100 percent organic,’ ‘organic,’ or ‘made with organic (specified ingredients or food group(s))’ must be certified according to the provisions of subpart E of this part and must meet all other applicable requirements of this part.”

For an IGC looking to grow products that they offer as “organic,” they are required to get those products certified before being able to use the “organic” term. The penalty can be quite severe. “Civil penalty for knowingly labeling or selling a product as organic except in accordance with the Organic Foods Production Act of 1990...has a maximum of $21,689.”

What allows a product to be called organic? Simply:

• It needs to be produced according to the NOP federal regulations.
• It needs to be certified.

What doesn’t allow a product to be called organic?

• Just using organic growing or potting mix.
• Just not using sprays or synthetic products on the plants.
• Just buying organic seed.
• Doing all these together doesn’t allow the use of the term “organic.”

As you can see, certification is the key to permitted use. Without that, it is against federal regulations to use the term “organic,” and the fines can be extensive.

The great news for IGCs looking to offer certified organic products is that the certification process is not that complicated, and the costs are minimal and easily offset by the marketing value of “organic.” The same records you are likely keeping now — seed sources and purchases, inputs used and sales of organic products — are most of what is required. There are federal and state grants that help offset some of the costs. Finally, each year, there is an inspection to review records and answer any questions.

Another easy option for IGCs to start offering certified organic products is to reach out to their local farmers or contact a wholesale grower that offers certified organic products. The NOP exempts from certification retail establishments “that [do] not process organically produced agricultural products or “that [process], at the point of final sale, agricultural products certified under this part as ‘100 percent organic,’ ‘organic,’ or ‘made with organic (specified ingredients or food group(s)).’”

In choosing a source for your organic product offering, be sure to ask the most important question: “Are you certified?”

On another note, the September article also touched on the quality of organic plants potentially not being as high as synthetically produced plants. This is a fallacy that some in the organic market use when things don’t grow right for them. Organic starter plants, when properly grown and cared for, will have the same if not better quality as those grown synthetically. Organic growing relies more heavily on the nutrients being added into the growing mix, where the plant takes them up through their roots. This is the normal method for nutrient uptake for plants. Conventional growers rely more on foliar application of nutrients. This allows for more control and customization of the feeding, but it is not the normal method of uptake.

An organic growing mix with the right balance of nutrients and biology will provide most veggie, herb and flower plants with the required nutrients to grow healthy and strong and look great. Organic plants will typically outperform conventional plants because they have been grown with the nutrients available at their roots, which is how home gardeners will grow them. Many times, there are still nutrients available in the container continuing to feed the plant when it goes to its new home. With foliar feeding, there isn’t much storage of nutrients. Most home gardeners won’t foliar feed their plants but rather just plant them in soil or potting mix, so it takes time for conventionally grown plants to adjust (transplant shock). A properly grown organic plant will exhibit less transplant shock and start growing/enjoying its new home quicker. Given the short growing season in the Midwest and some other regions, reducing transplant shock can mean a big difference in yield.

Randal Kohn is the owner of West Star Organics, a certified organic wholesale and retail garden center. West Star Organics has been certified organic since the National Organic Program’s inception in 1999. It is one of the oldest and largest certified organic greenhouse operations in Wisconsin.