Historically, many operations have farmed organically and advertised their products with an “organic” label, without being certified. For small farms, this approach avoids additional costs and administrative overhead, and is generally viewed to be “consumer certified”. These farms lack the same controls that certified farms who bear a compliance burden have.

In 2019, the USDA NOP launched a new database to aid in their compliance efforts. The agency noted that the new tool would allow their team to better track case progress and identify “patterns and relationships across complaints”.

Fraud remains a high priority that is addressed within the Strengthening Organic Enforcement Act (SOE) and is primarily focused on imports. Import oversight includes 5 major areas:

1) Farm-level yield analysis
2) Ship-specific surveillance
3) Fumigation investigations
4) Supply chain research
5) Country-commodity studies

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