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SOE: Labeling, Exemptions

March 1, 2024

SOE: Labeling, Exemptions, Organic Certificates, and updates to Normative Documents

Leading up to the implementation of the Strengthening Organic Enforcement (SOE) Rule approaching on March 19, 2024, this article is in relation to the regulation change regarding: Labeling, Exemptions, Organic Certificates, and updates to Normative Documents.
Changes were made to the Non-Retail labeling requirements. The key points are:
  • The audit trail documentation for the Non-Retail packaging/containers must identify the last certified operation that handled the agricultural product.
  • The Non-Retail packaging/containers must contain:
    • (1) Identification of the product as organic; and
    • (2) The production lot number, shipping identification, or other unique information that links the container to audit trail documentation.
Please refer to our label guidance document for further guidance.
PAO’s stance in regards to exempt operators is that we will strongly recommend all operators in the supply chain to be organic certified. PAO will follow the guidance of the NOP, and will not look for exemptions for you and the operators you choose to work with. It will be your responsibility as a certified operator to conduct a supply chain analysis and determine if the supplier’s you work with need to be certified.
We have updated our Master Supply Chain and Product List document to assist with ensuring you effectively communicate pertinent information about your supply chain to us, and can easily track all of your suppliers. This updated document is now available, and is attached to this communication. After today, this new Master Supply Chain and Product List document will be required to be completed for all operators.
Organic Certificates
Following March 19, 2024, all operators will receive an Organic Certificate generated through the Online Integrity Database (OID). In addition, you will continue to receive PAO’s Organic certificate which will include more detailed information about your operation. Both certificates are valid, however PAO’s organic certificate will now be considered an “Addenda” to the OID Certificate. PAO’s Organic Certificate will be updated to include your linking OID identification number.
Please be aware that on March 19, 2024, the OID will automatically generate an electronic certificate for all certified organic operations registered as USDA NOP site entities.
Failure to Comply
Failure to not meet these new requirements after March 19, 2024, may result in Non-Compliances or further adverse actions. For information on all SOE updates, click here.
Addtional Information
For Information on all SOE updates, click here.
If you have any questions regarding Strengthening Organic Enforcement, please do not hesitate to contact us at: or 805-623-5248.