October 5, 2020

PCC submitted comments on the National Organic Program’s (NOP) Strengthening Organic Enforcement (SOE) proposed rule, aimed at addressing the issue of organic fraud and improving the integrity of the organic supply chain.

The SOE proposed rule would update and modernize the organic regulations to reduce opportunities for fraud and improve oversight and enforcement in the organic supply chain. The rule would implement the most significant changes since the publication of the original federal organic regulations in 2000.

In addition to providing our own comments, PCC also contributed and signed on — as a full member — to the extensive comments submitted by the National Organic Coalition (NOC). Read NOC’s SOE Comments.

Overall, PCC supports the objectives of the SOE to provide better clarity and systems to prevent fraud in the organic supply chain. However, as a certified organic retailers PCC also made several recommendations on how the SOE rule could strengthen organic integrity even more, including reducing the amount of exempted operations, broadening to scope of the “handle” and “handling” definitions to include more entities, shortening the time frame allowed for submission of import certificates, and requiring labeling on more types of storage and transport containers.

Read PCC’s full comments on the SOE rule here.

October 5, 2020

PCC submitted comments on the National Organic Program’s (NOP) Strengthening Organic Enforcement (SOE) proposed rule, aimed at addressing the issue of organic fraud and improving the integrity of the organic supply chain.

The SOE proposed rule would update and modernize the organic regulations to reduce opportunities for fraud and improve oversight and enforcement in the organic supply chain. The rule would implement the most significant changes since the publication of the original federal organic regulations in 2000.

In addition to providing our own comments, PCC also contributed and signed on — as a full member — to the extensive comments submitted by the National Organic Coalition (NOC). Read NOC’s SOE Comments.

Overall, PCC supports the objectives of the SOE to provide better clarity and systems to prevent fraud in the organic supply chain. However, as a certified organic retailers PCC also made several recommendations on how the SOE rule could strengthen organic integrity even more, including reducing the amount of exempted operations, broadening to scope of the “handle” and “handling” definitions to include more entities, shortening the time frame allowed for submission of import certificates, and requiring labeling on more types of storage and transport containers.

Read PCC’s full comments on the SOE rule here.