USDA Organic: What does it Really Mean?

USDA Organic: What does it Really Mean?

  • By Ralph Morini
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  • November 2020-Vol.6 No. 11
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  • 1 Comment

“Organic” is a word with many meanings. In agriculture it signifies a belief system that embraces holistic natural farming processes. In our food system, the USDA has imposed regulations to ensure that specific “organic” practices are followed in the production of crops, livestock, processed products, and wild crops. This article will outline the history, scope and practices of the USDA organic program while assessing the health, environmental implications and significance for home gardeners.

History and Program Structure

While gardening using natural practices dates back centuries, the current organic movement blossomed during the 1950s and 1960s when the drawbacks of synthetic chemical farming became apparent. In the 1990s the US government created a structure to define and manage organic production practices from farm through retail. Highlights of this process include:

  • The Organic Foods Production Act (OFPA) (1990) charged the USDA with defining organic production practices.
  • The National Organic Standards Board (NOSB) (1992) was formed to advise the USDA on substances whose use is allowed or prohibited. It created rules that were reviewed by the EPA and FDA and implemented in 1997.
  • The National Organic Program (NOP) was formed in 2002. The NOP, a public-private partnership, develops and enforces uniform practices for organic production of agricultural products in the US.  The NOP is also responsible for accrediting the third-party organizations (“accredited certifiers”) to certify that farms and businesses meet the national organic standards.
  • The Organic Materials Review Institute (OMRI) is a non-profit organization that tests and maintains lists of allowed and prohibited input materials, including fertilizers, pesticides and additives, for inclusion in the NOP. The program focuses on practices believed to positively affect both the environment and production process. They don’t deal directly with the end products.
  • Producers are certified as organic by the NOP-accredited certifiers mentioned above, which may be private or governmental organizations.  A producer’s certification is audited and renewed annually.
  • All certified organic producers must maintain an Organic System Plan that outlines the practices and procedures they will follow to comply with regulations.
  • There are currently in excess of 22,000 certified organic operations globally, supplying a growing US market totaling about $43 billion in annual sales.

Imported organic banana with USDA label. Photo: Ralph Morini

What do the regulations cover?

Different food categories have individually-defined requirements:

Cultivated Crops:

  • Must be grown in soil with no prohibited substance additions for three years before they can be labeled organic
  • Prohibited substances include most synthetic fertilizers and pesticides.
  • Prohibited substances may be permitted where absolutely necessary, with approval, based on their having no negative human health or environmental impact

Livestock, including animals used for food, fiber or feed:

  • Must be provided living accommodations consistent with their natural behaviors
    • Year-round outdoor access
    • Pasture grazing at least 120 days per year
    • Ruminants must get 30% of dry food intake by grazing during the grazing season
  • Must be fed 100% organic feed and forage
  • No antibiotics or growth hormones are allowed

Processed foods that are handled, combined, processed and/or packaged:

  • Must be made with certified organic ingredients
  • No artificial preservatives, colors or flavors
  • Permitted exceptions only where there is no choice

Wild Crops, such as mushrooms and maple syrup, are subject to the same prohibitions as managed crops. They include items grown on defined uncultivated growing sites that are sustainably grown. Management activity is limited to reseeding, pruning and non-native plant removal.  There are specific regulations for harvesting of a certified organic wild crop.

There are multiple levels of USDA organic certification:

  • 100% Organic: all ingredients and processing aids must be certified organic
  • Organic: 95% of ingredients are certified://www.ams.usdanic
  • Made with Organic: at least 70% of ingredients are certified organic, excluding salt and water. The remaining ingredients are not certified organic but are produced without specifically-excluded methods such as genetically modified organisms (GMO), irradiation, or sewage sludge.
  • Products with less than 70% organic ingredients have no USDA label, but can list certified organic ingredients on their label.

Standards and Practices:

The NOP provides the national standards for organically enhancing soil quality, reducing pollution, and providing natural livestock habitats; it generally promotes sustainable farming practices. It is prescriptive in prohibiting the use of certain substances. For example, NOP disallows use of synthetic fertilizers and pesticides, while encouraging use of natural soil building processes. It requires specific practices for composting, for instance, that are designed to minimize risks of pathogen transmission to soils. Many organic soil amendments are permitted, including fertilizers like kelp, guano, bone meal, blood meal, and fish emulsion derived from natural, organic sources. Permissible unprocessed soil amendments, like raw manures, don’t have their chemical contents measured as they would if processed and packaged. Their use makes regular soil testing important to assure adequate nutrient availability.

Among key prohibitions are:

  • Use of synthetic fertilizers and pesticides
  • Sewage sludge as fertilizer
  • Irradiation to preserve food
  • GMO seeds, crops and additives
  • Antibiotics and growth hormones for livestock.

Compost must heat to at least 130º F for 3 days. Photo: Ralph Morini

NOP regulations are prescriptive in some areas of soil building. For example:

  • If raw manure is used to fertilize soil where crops are grown for human consumption, it must be incorporated 90 days prior to harvest for crops whose edible parts have no soil contact and 120 days prior for crops with soil contact.
  • Compost that utilizes animal products must be certified to reach temperatures of 131° to 170°F for varying periods of time, depending on composting method, to kill pathogens.

The NOP also includes soil fertility standards that address:

  • Tillage and cultivation practices to maintain/improve the physical, chemical, and biological condition of soil, while reducing erosion
  • Utilizing techniques including crop rotation, cover crops, and application of plant and certain animal-derived amendments
  • Managing soil additions to avoid contamination by nutrients, pathogens, heavy metals, and residues of prohibited substances.

The NOP doesn’t prescribe how these standards are applied. The result is that some early low-tech, green elements of “organic” farming can be lost to larger “industrial” farms that follow the guidelines but otherwise utilize mechanized practices and long haul transportation to get their products to market. Their organic produce is free of synthetic additives but has a larger than commonly understood carbon footprint.

Continuing Controversies: GMO Products and Hydroculture

The meaning of organic continues to be debated. For example, while current regulations don’t allow any GMO products to be labeled organic, there is discussion about whether GMO crops that are grown organically have a place in the program.

On the other hand, hydroponic and aeroponic producers, which grow crops in nutrient solutions and using nutrient misting techniques respectively, can be certified organic if their inputs are organic. Aquaponics however, which grows crops along with fish in a nutrient dense solution, is not certifiable as organic. The controversial difference is that aquaponic inputs have no connection to soil whatsoever. These designations are disputed but represent current NOP regulations.


The Agricultural Marketing Service (AMS) arm of USDA has enforcement oversight of the program and the certifiers do most of the policing of certified growers. They do scheduled annual and unannounced inspections, analyze sample products for prohibited substances, investigate complaints and allegations, and can issue various citations up to and including revocation of certification. AMS audits certifiers, investigates complaints, and can suspend or revoke certification and impose financial penalties to offenders.

There have been significant instances of fraudulent certified organic labeling, both domestically and from foreign suppliers. However, USDA defends its effectiveness at enforcement, and the consistently lower levels of pesticides in tested certified organic vs conventional produce indicate that overall, the program is working.

What about “Natural”?

The FDA has no formal rules defining “natural” in foods. They do have a longstanding informal policy that restricts “natural” to mean foods that are minimally processed with nothing artificial or synthetic, including color additives that don’t fundamentally alter the product. The label must define the meaning of natural, for example: minimally processed, no artificial ingredients, etc. The policy doesn’t address production methods, use of pesticides, processing or manufacturing methods including irradiation. GMO products are not excluded. It bears no relationship to nutritional or health benefits.

The policy is only loosely enforced. FDA occasionally sends letters to potential offenders but most enforcement happens via consumer driven lawsuits. Basically, an informal rule, lightly enforced, it is largely meaningless, more a marketing tool for food sellers than a benefit to consumers. The FDA has been considering formalizing their position since 2015, but has not taken a firm position yet. Best advice is to read the ingredient label carefully.

Photo: Image by Darren and Brad is licensed under CC BY-NC-SA 2.0

Is it Healthier to Eat Organic?

This is a loaded question. While there is a definite perception that organically produced food is “cleaner” than conventionally grown or processed products, proven health benefits are less established. What appears to be consistent over many studies includes:

  • A 30% lower risk of pesticide contamination in organic produce. Note however that residues found in conventional produce are within the USDA’s allowable safety limits
  • Organic chicken and pork provide a reduced exposure to antibiotic resistant bacteria
  • Organic dairy and meat products are higher in omega-3 fatty acids
  • Organic produce is higher in anti-oxidants, anthocyanins, and flavonols, which offer a variety of benefits including heart health and anti-inflammatory effects.

What is unproven is whether these differences provide measurable health benefits to organic consumers.

Overall nutritional content of organic and conventional produce is more a function of soil nutrient content and agricultural practices than whether they are organic or conventionally grown.

Environmental Impacts

While there is ongoing debate about whether organic food production is a practical way to feed the world, it is clearly better for our planet. Building soil quality by recycling plant wastes, composting, crop rotation, cover cropping, and mulching reduces farming’s carbon footprint, CO2 emissions, erosion and nutrient runoff. The drawbacks of heavy synthetic fertilizer use include soil depletion, higher input expenses, questions about toxicity and carcinogenicity of pesticides to humans as well as to insects, birdlife, and bio-diversity generally.

The indiscriminate use of antibiotics on livestock is a clear contributor to the reduced effectiveness of antibiotics and increasing threat of drug resistant bacteria in our lives.

That organic practices are preferable for the health of the planet and all its inhabitants is clear. How to transition conventional commercial agriculture toward a less environmentally harmful set of practices economically and without sacrificing production is a critical question of our time.

In the end, a hybrid system that emphasizes natural practices with “as needed” rather than preemptive chemical use is likely the most practical solution. For this to happen, continued evolution and growth of organic agricultural methods is necessary.

Beyond Organic 

For purists, it is possible to find food that is grown under stricter requirements than the NOP. One example is the Regenerative Organic Certification program. It is committed to 3 key tenets:

  • Soil health and land management
  • Animal welfare
  • Farmer and worker fairness.

It is consistent with the NOP but goes further. For example, soilless systems are completely disallowed, animals must be allowed to express normal behavior and have full time pasture access and there are a number of social fairness requirements for farm workers. Learn more at

For beef, pork and dairy products, the American Grassfed Association also provides a certification that exceeds USDA requirements and includes pasture raising, grass feeding from weaning to harvest (grass-fed and grass-finished), and is focused on American family farms. Their program is outlined at  It appears that there is no federal oversight on use of the grass-fed label, EXCEPT for producers who voluntarily seek certification by the American Grassfed Association. How the beef you buy was raised is not really made clear by its labeling.   Organic requirements are described above. USDA Organic, grass fed and grass fed and finished all are defined differently.

This article on beef labeling from Discover Magazine helps clarify the differences.

What about Home Gardeners?

While acknowledging that pure organic gardening is somewhat aspirational, a minimum chemical approach is realistic. Some practical steps we can take to get there include:

  • Follow an Integrated Pest Management approach to chemical use, applying synthetics only as needed, never preemptively.  Read more about it in the article Integrated Pest Management from the May 2020 issue of The Garden Shed.
  • Create a diverse environment to strike a balance between beneficial and harmful pests from soil life to insects to birds. Manage plant damage rather than trying to obliterate pests. For more on this read Natural Pest Control: Attracting Beneficial Insects from the June 2020 issue of The Garden Shed.
  • Compost yard and kitchen waste and add to gardens. Use organic fertilizers that promote soil organism growth and break down slowly and naturally. Get your soil tested and limit synthetic fertilizer use to what is needed for plant health.
  • Consider using organic seeds. They come from organically grown parents and have survived to the seed saving stage. They are arguably more pest and disease resistant than seed from plants that have been helped through the growing season by synthetic chemicals.

The Takeaways

The National Organic Program defines the way certified organic crops, livestock, and processed foods are grown, raised and handled from farm to retailer. It doesn’t define finished product characteristics.

Organic practices resemble nature’s practices and offer many environmental benefits, including a smaller carbon footprint, especially when foods are locally grown.

Nutritionally, organic foods are not demonstrably superior to conventionally-grown foods, but they clearly reduce consumer exposure to pesticide ingestion and appear to offer some potentially beneficial nutritional advantages. The effect on consumer health has not yet been effectively measured.

To those of us who aspire to become greener in our gardening practices and daily lives, it makes sense to support organic practices and buy local organic produce where available and when we can afford it.

We need to understand that the investment that commercial agriculture has in conventional methods combined with the need to feed the world would make a fast transition to minimum chemical food production difficult. Nevertheless, we need to start bending the curve in that direction now.


Cover photo: “20160802-RD-TPE-0179” by USDAgov is licensed under CC PDM 1.0 General explanation of  USDA Organic labels, USDA. GMO prohibition for organic products, USDA. Meaning of different levels of organic, USDA.  Explanation of “Organic”.   An Introduction to Organic Certification Requirements, Nutritional effects of organic, Mayo Clinic. Organic regulations, USDA. NOP explanation, USDA. Organic nutrition impact, Stanford University Nutrition effects of organic, NIH. Nutrition effects of organic, NPR , What Makes Grass Fed Beef Different, Are You Buying the Real Thing?, Megan Schmidt, Discover Magazine, July 17, 2020.


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