Strengthening Organic Enforcement (SOE): What U.S. Organic Businesses Need to Know
The U.S. organic market has entered a new era of oversight. The USDA Strengthening Organic Enforcement (SOE) rule expanded certification and traceability requirements across the organic supply chain, affecting many businesses that import, export, trade, sell or facilitate the sale of organic products in the United States.
With the rule fully implemented since March 19, 2024, understanding whether your business falls within its scope is essential for maintaining access to the U.S. organic market.
What is the Strengthening Organic Enforcement rule?
The Strengthening Organic Enforcement rule, commonly known as SOE, is a USDA National Organic Program (NOP) regulation designed to strengthen oversight and enforcement of organic production, handling and trade.
One of its most significant changes is the expansion of USDA organic certification requirements to additional businesses throughout the supply chain. Operations that previously may not have required certification may now need to become certified under the USDA National Organic Program, unless they qualify for a specific exemption.
SOE also strengthens supply chain traceability, recordkeeping, import oversight and fraud prevention.
Who needs to be certified under SOE?
If your company works with organic products in the United States, it is important to determine whether the new requirements apply to your activities.
Businesses that import, export, trade, sell or facilitate the sale of organic products may now require USDA organic certification. This can include businesses that do not physically handle the product but participate in its sale or trade.
Some operations may qualify for exemptions, so certification requirements should be evaluated according to the company’s specific activities and role within the organic supply chain.
What does SOE mean for organic imports?
- SOE introduced important requirements for companies importing organic products into the United States.
- Organic products imported into the U.S. generally need to be associated with an electronic NOP Import Certificate. The certificate provides information about the organic shipment and is intended to improve traceability and oversight of organic imports entering the country.
- For importers and businesses working with international suppliers, this makes coordination across the supply chain increasingly important.
How can businesses prepare for SOE compliance?
Organizations involved in U.S. organic trade should understand their position within the supply chain and determine which certification and documentation requirements apply.
Some useful first steps include:
- Identifying your role in the organic supply chain.
- Confirming whether your operation requires USDA organic certification.
- Reviewing the certification status of relevant suppliers and business partners.
- Ensuring appropriate traceability and recordkeeping systems are in place.
- Understanding NOP Import Certificate requirements when importing organic products into the United States.
Taking these steps can help businesses identify compliance gaps before they affect organic trade activities.
How Control Union can help
Control Union provides USDA NOP organic certification services and supports businesses operating across international organic supply chains.
Whether you are an importer, exporter, trader, handler or other participant in the organic sector, our team can help you understand the certification process and determine the requirements relevant to your operation.