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Organic 101: What Organic Farming (and Processing) Doesn’t Allow

The USDA organic label on dairy or meat products means that the animals from which it originated were raised in living conditions that accommodated their natural behaviors, without being administered hormones or antibiotics, and while grazing on pasture grown on healthy soil.  Photo by Ryan Thompson.

The USDA organic label on dairy or meat products means that the animals from which it originated were raised in living conditions that accommodated their natural behaviors, without being administered hormones or antibiotics, and while grazing on pasture grown on healthy soil. Photo by Ryan Thompson.

This is the first in series of Organic 101 pieces that will explore the different rules within the USDA organic regulations.

When it comes to organic foods, it’s just as important to know what isn’t allowed as what is.  The organic standards are process-based, meaning they establish the rules for an entire system of farming that follows a product from its beginnings on the farm all the way to retail.

Organic products are managed according to defined processes for planting, growing, raising, and handling. For example, the USDA organic label on dairy or meat products means that the animals from which it originated were raised in living conditions that accommodated their natural behaviors, without being administered hormones or antibiotics, and while grazing on pasture grown on healthy soil. Then during processing the meat or dairy product was handled in a facility that was inspected by an organic certifier and processed without any artificial colors, preservatives, or flavors before being packaged to avoid contact with any prohibited, nonorganic substances.

A very important part of the process-based regulatory framework is the prohibition of certain methods in organic production and handling. Methods like irradiation, sewage sludge, and genetic engineering are all expressly prohibited from being used when growing or processing organic foods.

Genetic engineering in particular has drawn a lot of attention and concern from consumers and the organic community. In April 2011, the National Organic Program (NOP), a part of the USDA’s Agricultural Marketing Service, issued a policy memo that explained the relationship between genetically modified organisms (GMO) and food production under the organic standards.

The USDA organic regulations prohibit the use of GMOs, listing them as “excluded methods,” and defining those methods as “a variety of methods to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes…. Such prohibited methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology).”

To prevent GMOs from being introduced into organic production, producers do not use genetically modified seeds or other materials when planting crops.  They also work with their certifiers to implement preventative practices that effectively buffer their farms from GMO contamination.

Organic food handlers and processors also ensure that their ingredients are not produced from excluded methods.  Certifying agents review and audit all of ingredients–not only the agricultural ingredients but also others that are allowed in organic processing, like baking soda, yeast, dairy cultures, and vitamins–to verify that they are not genetically modified.

All of these measures are documented in operations’ organic systems plans, a crucial element of USDA organic certification that outlines detailed practices and procedures addressing how operators comply with the requirements of the organic regulations.

No matter where the product is grown or how the product is made, if it has the USDA Organic label on it, genetic engineering or genetically modified organisms are not allowed.

Look for part 2 of this series where we will explain the process for approving or prohibiting substances in organic foods.

11 Responses to “Organic 101: What Organic Farming (and Processing) Doesn’t Allow”

  1. Chris Downs says:

    I am interested in finding out how you manage the introduction of different fish species into aquaculture. My understanding is that fish farming can also be certified organically. When you certify fish farms organically or being organic take it you must consider the fish meat.

    If the fish are raised in tanks how do you manage sharing the effluent of the tanks has been certified organic fertilizer or used in compost. I like this series as it is very helpful for me and others as we choose the farm protocols that we use.

  2. USDA Spokesperson says:

    We’re glad to know you find the blogs in this series helpful to your understanding of the organic regulations. In response to your question, the USDA does not currently have organic standards specific to aquaculture or aquaculture products. The National Organic Program ( does plan to incorporate these standards as part of the organic regulations in the next couple of years. To keep updated about developments in this area and about public commenting during the rulemaking process, you’re welcome to sign up for Organic Insider email updates at

  3. Brendan Bombaci says:

    In § 205.204 “Seeds and planting stock practice standard,” of the Organic Program regulations, (1) Nonorganically produced, untreated seeds and planting stock may be used to produce an organic crop when an equivalent organically produced variety is not commercially available: Except, That, organically produced seed must be used for the production of edible sprouts, (3) §205.290(a)(2) nonorganically produced annual seedlings may be used when there has been damage caused by drought, wind, flood, excessive moisture, hail, tornado, earthquake, fire, or other business interruption, (4) Nonorganically produced planting stock to be used to produce a perennial crop may be sold, labeled, or represented as organically produced only after the planting stock has been maintained under a system of organic management for a period of no less than 1 year, and (5) Seeds, annual seedlings, and planting stock treated with prohibited substances may be used to produce an organic crop when the application of the materials is a requirement of Federal or State phytosanitary regulations.

    With these things in mind, it seems entirely true that geneticaly modified organisms may be utilized to manipulate a plant strain whose future seeds and seedlings may be entered into the organic program after one year of organic management thereafter – in the very least (not including emergency climatic or supply situations, whereby nonorganics can apparently be used and labeled as organic). I would add that this could be happening all the time, since GM is only an excluded “method” in the regulations, and not an excluded “crop stock” or “seed” or “breed,” etc. So as long as that method is not being used *during* engagement with the organic program, stock could already be GM, and by the books.

    If this is not the intention of the Organic Program representatives, I would suggest modification of the legal text.

  4. Lia Cairone says:

    Are animal products such as meat, poultry, egg and dairy products labeled as USDA Organic prohibited from using animals which have been fed genetically modified foods?

  5. Teresa says:

    I echo Lea’s question. Any response?

  6. Matt Smith says:

    Lia, here is the URL for the regulations for Organic products. The answer you are looking for is in §205.301(e) (below). From my understanding, organic labeling of feed pretty much follows the same guidelines as all other organic consumables.

    “Livestock feed.

    (1) A raw or processed livestock feed product sold, labeled, or represented as “100 percent organic” must contain (by weight or fluid volume, excluding water and salt) not less than 100 percent organically produced raw or processed agricultural product.

    (2) A raw or processed livestock feed product sold, labeled, or represented as “organic” must be produced in conformance with § 205.237.

    (f) All products labeled as “100 percent organic” or “organic” and all ingredients identified as “organic” in the ingredient statement of any product must not:

    (1) Be produced using excluded methods, pursuant to § 201.105(e) of this chapter;

    (2) Be produced using sewage sludge, pursuant to § 201.105(f) of this chapter;

    (3) Be processed using ionizing radiation, pursuant to § 201.105(g) of this chapter;

    (4) Be processed using processing aids not approved on the National List of Allowed and Prohibited Substances in subpart G of this part: Except, That, products labeled as “100 percent organic,” if processed, must be processed using organically produced processing aids;

    (5) Contain sulfites, nitrates, or nitrites added during the production or handling process, Except, that, wine containing added sulfites may be labeled “made with organic grapes”;

    (6) Be produced using nonorganic ingredients when organic ingredients are available; or

    (7) Include organic and nonorganic forms of the same ingredient.”

  7. Pam says:

    I am more concerned about what is actually being assured by USDA-Organic labels. The USDA-Organic label is described here as claiming the foods are “sludge-free”, when the whole idea behind the nation’s endorsement of “beneficial biosolids” was to modify the name so that it did not sound like “sludge”. Does a USDA-Organic label on any given package assure that NO “BIOSOLIDS” were placed in or on the soil that grew that food?

  8. Edward Richardson says:

    I have been told that some pesticides are allowed in organic farming. What are these pesticides?

  9. ann jablonski says:

    I am confused about Canola oil. It was first introduced in Canada for car oil. How can it be called organic?

  10. Ben [USDA Moderator] says:

    @ann jablonski – thanks for your comment. Canola oil comes from the seeds of the canola plant. Since this is an agricultural product, it can be certified organic as long as it meets the organic production and handling requirements. You can learn more about organic production online at

  11. Dawn Lauryn says:

    ATTN: USDA, Please address the comment made by Brendan Bombaci on
    08/09/2012 at 6:30 PM. Is there a specific exclusion that prohibits GMO seedlings from being used under these circumstances? This appears to be a potential large gaping loophole threatening the integrity of the USDA Organic labeling standards. If such a loophole exists, how are we to know is our food is or isn’t genetically modified? If there is a policy, please reference the CFR#.
    Thanks in advance.

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